Of course, as is true with most honest services fraud questions, the privileged relationship context was affected by Skilling. The Skilling decision mandated the requirement of a fiduciary relationship, which is certainly present in a privileged relationship such as a client and his attorney. It is less clear whether Skilling limited the applicability of the statute to only bribery and kickback schemes in this setting. Certainly a plaintiffs attorney who took kickbacks from a corporation in exchange for a lower settlement would be eligible for prosecution. On the other extreme, the honest services statute would never be construed to outlaw all non-disclosures between an attorney and his client. The question is yet to be resolved by the high courts, but it is clear that bribery and kickback schemes are prohibited by the statute, along with most likely any failure to disclose information for purposes of illicit financial gain.