News & Analysis as of

Disgorgement Appeals

Bradley Arant Boult Cummings LLP

SEC Disgorgement Stuck in Circuit Split After Supreme Court Declines to Intervene

On June 6, 2025, the U.S. Supreme Court denied a petition for certiorari in Navellier & Associates, Inc. v. SEC, declining to resolve a circuit split regarding the circumstances under which the U.S. Securities and Exchange...more

Troutman Pepper Locke

Supreme Court Denies Certiorari in SEC Disgorgement Case

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On June 6, the U.S. Supreme Court denied the petition for certiorari in the case of Navellier & Associates, Inc. v. Securities and Exchange Commission (SEC). This decision effectively upholds the lower courts’ rulings,...more

Foley & Lardner LLP

First Circuit’s Reversal of Summary Judgment Clarifies Materiality Standard for Advisory Conflicts

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A recent ruling may raise the bar for the Securities and Exchange Commission (SEC) in charging registered investment advisers for omissions of potential conflicts and seeking disgorgement, giving the defense bar additional...more

Troutman Pepper Locke

SEC Briefs Disgorgement and Investor Harm in Navellier v. SEC

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In the recent Supreme Court case, Navellier & Associates, Inc. v. Securities and Exchange Commission (SEC), the petitioners sought a writ of certiorari challenging the decisions of the lower courts regarding the scope of...more

Eversheds Sutherland (US) LLP

SEC v. Commonwealth: a win for the securities industry

On April 1, 2025, the First Circuit Court of Appeals vacated a nearly $95 million judgment against our client Commonwealth Financial Network related to the sufficiency of Commonwealth’s revenue-sharing disclosures. The First...more

Morgan Lewis

First Circuit Vacates $93 Million Judgment for SEC, Including $65 Million Disgorgement Award

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On April 1, the US Circuit Court of Appeals for the First Circuit vacated a $93 million judgment for the SEC against Commonwealth Financial, including a $65 million disgorgement award. The three-judge panel concluded that the...more

Ropes & Gray LLP

First Circuit Vacates Summary Judgment Award and $93 Million Order in Revenue Sharing Case

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On April 1, 2025, the United States Court of Appeals for the First Circuit overturned a $93 million judgment issued against Commonwealth Financial Network (“Commonwealth”) nearly one year ago in a case by the Securities and...more

McDermott Will & Schulte

When Is a Trade Secret Accessible? As Soon as It Can Be Reverse Engineered

Although the US Court of Appeals for the Federal Circuit upheld a damages award for trade secret misappropriation and breach of a confidentiality agreement, it found that the district court erred in its determination of when...more

Jones Day

First Circuit Reverses SEC Win in $93 Million Investment Adviser Disclosure Case

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The court rejects the SEC's per se materiality argument and requires proof of a causal connection between the defendant's allegedly inadequate disclosures and purported unlawful profits....more

Irwin IP LLP

Time To “Dew” It Again. 

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Dewberry Group, Inc., FKA Dewberry Capital Corp v. Dewberry Engineers Inc., No. 23-900, 604 U.S. (2025) - On February 26, 2025, the United States Supreme Court unanimously overturned a $43 million damages award arising out...more

Mintz - Intellectual Property Viewpoints

Whose Profits Are These, Anyway? Who Constitutes The Defendant For Purposes of Disgorgement Of Profits In A Trademark Infringement...

In a unanimous (and unsurprising) decision on Wednesday, the Supreme Court vacated an award of nearly $43 million in disgorged profits to a trademark infringement plaintiff because those profits were not attributable to the...more

Goodwin

Supreme Court Curtails Disgorgement in Trademark Infringement Case

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On February 26, 2025, the US Supreme Court issued a unanimous decision limiting the scope of an award of the “defendant’s profits” in trademark infringement suits under the Lanham Act, 15 U.S.C. §1117(a), to only those...more

Fenwick & West LLP

SCOTUS Stands by Corporate Separateness, Overturns Nearly $43M Award in Trademark Dispute

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The Supreme Court on February 26, 2025, overturned a nearly $43 million award granted in a decades long trademark dispute between two real estate companies. The unanimous ruling emphasized that under the Lanham Act section...more

Moritt Hock & Hamroff LLP

Supreme Court Upholds Principle Of Corporate Separateness In Vacating Award To Dewberry Engineers

n a decision that strongly endorsed the principle of corporate separateness – where a company’s affiliates are not financially responsible for the legal obligations of their parent – the U.S. Supreme Court unanimously...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Limits Lanham Act Disgorgement to Named Defendants’ Profits

On February 26, 2025, the U.S. Supreme Court ruled unanimously in favor of the petitioner in Dewberry Group Inc. v. Dewberry Engineers Inc., holding that a disgorgement of “defendant’s profits” under the Lanham Act may...more

ArentFox Schiff

Sue Them All? SCOTUS Vacates $43 Million Trademark Judgment

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To plead, or not to plead. That is a question trademark infringement plaintiffs will need to carefully consider with their legal counsel when deciding which parties to name as defendants in a lawsuit and which legal arguments...more

WilmerHale

Supreme Court Vacates Trademark Infringement Disgorgement Award for Failure to Observe Separateness of Corporate Affiliates

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On February 26, 2025, the Supreme Court decided Dewberry Group, Inc. v. Dewberry Engineers Inc., No. 23-900, a case concerning corporate separateness and disgorgement awards for Lanham Act trademark infringement....more

BakerHostetler

Supreme Court Upholds Corporate Separateness in Unanimous Dewberry Decision

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In Dewberry Group, Inc. v. Dewberry Engineers, Inc., the Supreme Court unanimously held that the Lanham Act does not permit courts to disregard corporate identity when awarding damages for trademark infringement....more

Fox Rothschild LLP

The U.S. Supreme Court Unanimously Rules That Successful Trademark Plaintiffs Cannot Recover Profits From Named Defendants’...

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On February 26, 2025, the U.S. Supreme Court unanimously vacated a nearly $43 million award in a trademark dispute that raised the question of whether a defendant’s affiliates could be held liable for payment of a disgorged...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Supreme Court Overturns Nearly $43 Million Trademark Infringement Award Based on Section 35 of the Lanham Act

The U.S. Supreme Court’s opinion in the Dewberry Group, Inc. v. Dewberry Engineers Inc. case was released Wednesday. In a unanimous opinion, the Court found that Section 35 of the Lanham Act, which provides that a plaintiff...more

McDermott Will & Schulte

Chill Out: Request for Profit Disgorgement Isn’t Entitled to Jury Trial

The US Court of Appeals for the Eighth Circuit affirmed a district court ruling that a plaintiff was not entitled to a jury trial regarding its trade dress infringement claim and that the plaintiff failed to prove that its...more

Bracewell LLP

A New Way to Pierce the Corporate Veil: Disgorging Profit From Corporate Affiliates

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The US Supreme Court has recently granted certiorari on the issue of whether a corporation can be held liable for the conduct of its affiliate without first satisfying the well-settled standards for piercing the corporate...more

McDermott Will & Schulte

Don’t Share Trade Secrets With Your Fiancé: A Cautionary Tale

The US Court of Appeals for the First Circuit largely affirmed a multimillion-dollar award against a temp agency for misappropriation of trade secrets and unjust enrichment due to its employee’s act of obtaining proprietary...more

McDermott Will & Schulte

David-Versus-Goliath Trademark Victory Isn’t “Exceptional”

The US Court of Appeals for the Third Circuit vacated an award of attorneys’ fees for reanalysis, explaining that the district court’s finding that the case was “exceptional” under the Lanham Act was based on policy...more

McDermott Will & Schulte

Gentlemen, Start Your Engines: Even Bland Works Support Copyright

The US Court of Appeals for the Sixth Circuit affirmed an award of profit disgorgement and attorneys’ fees in a copyright infringement case, holding that even “workaday” or “humdrum” subject matter can support a valid...more

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