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Second Circuit Broadens "Predominantly Foreign" Exception, Limiting Reach of U.S. Securities Laws

The Situation: In 2010, in Morrison v. National Australia Bank Ltd., the Supreme Court held that Section 10(b) of the Securities Exchange Act of 1934 applies to (i) "transactions in securities listed on domestic exchanges";...more

Second Circuit Breathes New Life Into Conduct And Effects Test

The Situation: Since the Supreme Court decided Morrison v. National Australia Bank Ltd. ("Morrison") in 2010 and rejected the Second Circuit's "conduct and effects test," the Second Circuit has grappled with the issue of...more

Second Circuit Concludes Commodity Exchange Act Claims Accrue When Plaintiffs Learn Of Their Injuries

Under the "discovery accrual rule" discovery of the injury starts the clock for statute of limitations purposes. On February 28, 2019, the Second Circuit issued an important decision regarding the statute of limitations...more

Tenth Circuit Holds Federal Securities Laws Apply Extraterritorially In Enforcement Actions

The Situation: The U.S. Court of Appeals for the Tenth Circuit recently addressed the issue of whether the antifraud provisions of the federal securities laws apply extraterritorially in enforcement actions commenced by the...more

Commodity Exchange Act: Key Decisions from 2018 and Enforcement Trends to Monitor in 2019

2018 was an interesting year for market participants subject to the Commodity Exchange Act ("CEA"), with federal appellate courts issuing three noteworthy decisions involving claims under the CEA. The Commodity Futures...more

Recent Second Circuit Decisions Assess Territorial Reach of Securities and Commodities Laws

The Situation: The Second Circuit has issued two decisions in recent months that have addressed whether the U.S. securities and/or commodities laws can be applied to transactions with significant foreign ties. Each of these...more

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