The article offers reasons why Steve Jobs is not likely to face criminal charges having to do with backdating his own stock options. Relating to that Professor Grundfest is quoted as saying:

"Jobs can take the defense, 'What do I know about the proper accounting for this transaction? I didn't keep a secret from anybody and assumed the accounting would be proper,'" said Joseph Grundfest, a Stanford law professor and former SEC commissioner. "That would seem to distinguish the Apple situation."