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SEC Dismisses In-House Proceedings Against Accountants Following Jarkesy

In the wake of the U.S. Supreme Court's recent Jarkesy decision, the U.S. Securities and Exchange Commission ("SEC") dismissed two contested Rule 102(e) proceedings against accountants, suggesting that the agency believes...more

SEC v. Jarkesy: Defendants Entitled to Jury Trial in SEC Fraud Actions

Seventh Amendment entitles defendants to jury trials when the SEC seeks civil penalties for securities fraud. ...more

U.S. Supreme Court Bars Liability for "Pure Omissions" Under Section 10(b) of Securities Exchange Act

The United States Supreme Court in Macquarie Infrastructure Corp. v. Moab Partners, L.P., No. 22-1165, ruled that a corporation is not liable under Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 for...more

Second Circuit Provides Valuable Guidance on Application of the Supreme Court's Price-Impact "Mismatch" Framework

In Short - The Situation: The United States Court of Appeals for the Second Circuit recently decertified a class of stockholders who alleged that Goldman Sachs maintained an inflated share price by making...more

Insider Trading Enforcement in 2022

Each year, the Department of Justice ("DOJ"), the Securities and Exchange Commission ("SEC"), and in recent years, the Commodity Futures Trading Commission ("CFTC") dedicate substantial resources to investigating and...more

Fifth Circuit Finds SEC Administrative Proceedings Unconstitutional

On May 18, 2022, the Court of Appeals for the Fifth Circuit ruled that key aspects of the SEC's in-house enforcement regime for securities fraud cases were unconstitutional. The decision, Jarkesy v. SEC, has significant...more

SEC Brings Landmark Suit Over Alleged Misrepresentations in ESG-Related Documents

The U.S. Securities and Exchange Commission's ("SEC") Climate and ESG Task Force has filed one of its most significant enforcement matters to date. On April 28, 2022, the SEC brought an action in the U.S. District Court for...more

SEC Announces Settlement of Fraud Case Without Requiring Financial Penalty in Recognition of Company's Substantial Cooperation

On January 28, 2022, the U.S. Securities and Exchange Commission ("SEC") announced a settled fraud case with HeadSpin, Inc., a technology start-up, that allegedly engaged in a scheme to boost the company's valuation to more...more

The Perils of Well-Intentioned Deception: Insider Trading Case Highlights Challenges Facing Public Companies

The Situation: Despite Equifax's use of a cover story to keep employees from learning it was the victim of a serious data breach, a then-employee allegedly figured it out and made illegal securities trades based on the...more

Supreme Court Dismisses Important Securities Case on Issue Likely to Arise Again

On June 18, 2018, the U.S. Supreme Court dismissed Leidos v. Indiana Public Retirement System, a securities case that raised important and unsettled issues about the scope of liability under Section 10(b) of the Securities...more

U.S. Supreme Court: Plaintiffs May Not Piggyback Successive Class Actions Beyond Statute of Limitations

When does time run out on filing a class action? Under the U.S. Supreme Court's seminal decisions in American Pipe & Construction Co. v. Utah and Crown, Cork & Seal Co. v. Parker, a timely class complaint tolls the statute of...more

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