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SDNY Rules Ripple’s XRP Token Was – and Was Not – a Security

On July 13, 2023, US District Judge Analisa Torres of the US District Court for the Southern District of New York ruled that Ripple Labs’ token, XRP, was a security when sold to institutional investors and not a security when...more

President’s Working Group Urges Congress to Take Action on Stablecoins

On November 1, 2021, the President’s Working Group on Financial Markets, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (together, the “Agencies”) released a report on...more

Alert: SBA Defines ‘Gross Receipts’ for Second Draw PPP Loans

On January 6, 2021, the Small Business Administration (SBA) issued two interim final rules related to Paycheck Protection Program (PPP) loans under the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act. In...more

Alert: Additional PPP Funding Available, Subject to New Eligibility Requirements

On December 27, 2020, President Trump signed into law the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act. Among other things, the act allocates additional funds to the Paycheck Protection Program,...more

Alert: SBA Issues Guidance for Borrower Changes of Ownership

The CARES Act established the Paycheck Protection Program (PPP) administered by the Small Business Administration (SBA) as part of the broader SBA 7(a) loans program. One of the 7(a) loan servicing limitations is that lenders...more

Alert: PPP Loan Forgiveness Application Released (Updated)

Loan forgiveness is a key feature of the CARES Act's Paycheck Protection Program administered by the Small Business Administration. On June 16, the SBA and Department of Treasury released a revised loan forgiveness...more

Alert: PPP Loan Forgiveness Application Released

As has been much discussed, loan forgiveness is a key feature of the CARES Act’s Paycheck Protection Program (PPP) administered by the Small Business Administration (SBA), but there has been little clarity regarding the...more

Alert: New PPP Loan FAQ - Limited Safe Harbors Related to Necessity Certifications

Yesterday, the Small Business Administration (SBA) issued Payment Protection Program (PPP) FAQ 46 providing limited safe harbors related to the necessity certification, but did not issue more clarifying guidance as to what...more

Alert: New PPP Loan FAQ: Safe Harbor Extended to May 14, 2020

A key aspect of the CARES Act relief package is the now-well-known Paycheck Protection Program (PPP) administered by the Small Business Administration (SBA). ...more

Alert: SBA PPP Loans – Calculations and Considerations for Maximizing Forgiveness

Loan forgiveness is a key feature of the Paycheck Protection Program (PPP) administered by the Small Business Administration (SBA) pursuant to the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). If PPP loan...more

Alert: PPP Loan Program – Fourth Interim Final Rule

On April 24, 2020, an additional $310 billion was authorized under the Paycheck Protection Program (PPP), a key aspect of the CARES Act relief package. The program, administered by the Small Business Administration (SBA),...more

Alert: SBA Programs Under the CARES Act: Are You Eligible for Federal Assistance?

As has been well publicized, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) is a $2 trillion economic relief package enacted to help individuals and businesses in the United States weather the severe...more

Alert: President Signs CARES Act

The President has signed a $2 trillion relief package, the "Coronavirus Aid, Relief, and Economic Security Act" (CARES Act). The CARES Act is intended to provide "emergency assistance and health care response for individuals,...more

Alert: Commissioner Peirce Proposes Token Safe Harbor for SEC and Industry Review

A way out of the ‘regulatory Catch-22’ for launching distributed networks? In a February 6 speech at the International Blockchain Congress in Chicago, Securities and Exchange Commission Commissioner Hester Peirce...more

Blog: Representation & Warranty (R&W) Insurance – Current Market Trends

Over the last decade the use of R&W insurance in merger and acquisition transactions has grown exponentially. From 2008 to 2018, the total R&W policies bound per year in North America rose from 40 deals, providing $541...more

Alert: SEC Qualifies First Token Offerings Under Regulation A

On July 10 and July 11, 2019, the US Securities and Exchange Commission (the SEC) qualified the Regulation A token offerings of Blockstack PBC and YouNow, Inc., nearly two years after the DAO Report and a year and half after...more

Alert: SEC Releases Long-Awaited ‘Plain English’ Guidance for Digital Assets and Investment Contract Analysis

On April 3, the SEC Division of Corporation Finance released a No Action Letter and a suggested framework for applying the investment contract analysis to tokens and digital assets....more

Alert: The Massachusetts Securities Division and its Recent ICO Actions

On March 27, 2018, Massachusetts' top securities regulator – the Massachusetts Securities Division (the Division) – propelled itself to the forefront of the ongoing debate about whether "initial coin offerings" (ICOs) should...more

Blog: The Art of Drafting Milestones for an Earn-Out

Former stockholders of SARcode Bioscience were recently denied a claim that they were entitled to be paid $425 million in milestone payments under a merger agreement. The decision provides an anecdotal lesson in drafting...more

Blog: Martha Stewart Decision Draws Roadmap for Controller Sales to Third Parties

A transaction involving a controlling stockholder on both sides of the deal presents a clear conflict of interest that will result in heightened scrutiny under the “entire fairness” standard of review if later challenged....more

Blog: Chicago Bridge Reversal Reiterates Need for Consistent Accounting in Working Capital True-Up

The vast majority of private company acquisitions contain some type of purchase price adjustment to account for any changes in certain financial metrics (including working capital) of the target between a specified reference...more

Blog: $2 Billion Purchase Price Dispute Over GAAP Compliance Highlights Need for Careful Drafting

Purchase price adjustments are common features (2015 SRS study: 77% of deals) of private merger agreements that are generally intended to ensure that the acquired company will have the same level of cash or working capital to...more

Blog: Dell Decision and Recent Amendments to Delaware’s Appraisal Statute

Section 262 of the DGCL provides a statutory remedy for stockholders who do not vote in favor of certain M&A transactions (generally cash mergers) to petition the corporation to buy their stock at a price equivalent to the...more

Blog: DE Court Comments on Block-Holder Rights in OptimisCorp

The Delaware Supreme Court issued an Order this week in OptimisCorp v. Waite that could have implications for VC-backed or other companies with so-called “block-holder” directors – or directors who are appointed by a...more

Blog: Private Market Trends Snapshot 2016

M&A deal terms will almost always vary based on the specific context of the transaction, including the deal price, structure and each party’s negotiating leverage. Although no amount of data can replace context-specific...more

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