The Second Circuit U.S. Court of Appeals upheld that investors in the Madoff Ponzi scheme, who withdrew more money than they invested net winners are not entitled to rely on fictitious profits shown in their last statements. Instead, the court ruled that losses and gains should be based on the actual money invested minus withdrawals. This decision aligns with other Ponzi scheme rulings, ensuring net winners cannot claim distributions as victims and are subject to claw-back lawsuits for their excess withdrawals plus interest.