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The effect of the American Meat Institute Decision on the Conflict Minerals Rule

As we have discussed over the last few months, the fate of the conflict minerals rule has been uncertain. In April 2014, in the National Association of Manufacturers (“NAM”) case, the Court of Appeals for the D.C. Circuit...more

9/4/2014 - American Meat Institute Appeals Conflict Mineral Rules En Banc Review First Amendment NAM

SEC Petitions for Rehearing of First Amendment Issues in Conflict Minerals Case

On May 29, 2014, the Securities and Exchange Commission petitioned the U.S. Court of Appeals for the District of Columbia Circuit for a rehearing of the First Amendment issues in the conflict minerals case. The SEC, however,...more

6/11/2014 - Conflict Mineral Rules Enforcement Actions First Amendment Free Speech SEC

Conflict Minerals Update: Court Denies NAM's Motion to Enjoin Enforcement, SEC’s June 2 Deadline Remains In Effect

On May 14, 2014, the U.S. Court of Appeals for the District of Columbia Circuit issued a per curium order denying the motion filed by the National Association of Manufacturers (“NAM”) to stay the SEC’s Conflict Minerals Rule....more

5/22/2014 - Appeals Conflict Mineral Rules Deadlines Enforcement Enforcement Actions NAM Reporting Requirements SEC

Conflict Minerals Rule Update: U.S. Court of Appeals for the D.C. Circuit Issues Per Curiam Order in Conflict Minerals Case

On May 7, 2014 the United States Court of Appeals for the District of Columbia Circuit filed a per curiam order in response to the appellant’s emergency motion for stay of the SEC’s Conflict Minerals Rule...more

5/8/2014 - Appeals Conflict Mineral Rules Motion To Stay NAM SEC

Conflict Minerals Rule Update: NAM Files Emergency Motion for Stay with D.C. Circuit Court of Appeals

Following through on its April 30 statement, the National Association of Manufacturers, joined by the U.S. Chamber of Commerce and the Business Roundtable, filed an emergency motion for stay of the SEC’s Conflict Minerals...more

5/6/2014 - Business Roundtable Chamber of Commerce Conflict Mineral Rules Motion To Stay NAM SEC

Conflict Minerals Rule Update: SEC Issues Order Confirming Guidance and Denies NAM Motion for Stay

On May 2, 2014, the SEC issued an order partially staying its Conflict Minerals Rule. Essentially, the order reiterates the SEC’s April 29, 2014, guidance that the Commission will not require companies subject to the conflict...more

5/5/2014 - Conflict Mineral Rules First Amendment Manufacturers NAM SEC

Conflict Minerals Rule Update: NAM Motion for Stay

As mentioned below, on April 29, 2014, the National Association of Manufacturers (NAM), Chamber of Commerce and Business Roundtable filed a motion for stay with the SEC. The motion requested that the SEC stay its final...more

5/5/2014 - Conflict Mineral Rules Disclosure Requirements First Amendment Form SD Motion To Stay National Association of Manufacturers

Conflict Minerals Rule Update: SEC Guidance and NAM Motion for Stay

The SEC issued guidance on its interpretation of the U.S. Court of Appeals for the D.C. Circuit’s recent decision that certain portions of the SEC’s conflict minerals reporting requirements violate the First Amendment...more

5/2/2014 - Conflict Mineral Rules First Amendment Manufacturers NAM SEC

U.S. Court of Appeals for the District of Columbia Circuit Holds That Portion of Conflict Minerals Rule Violates First Amendment

On April 14, 2014, the United States Court of Appeals for the District of Columbia issued its decision in the pending court challenge to the conflict minerals rule. The rule was promulgated in 2012 by the Securities and...more

4/29/2014 - Conflict Mineral Rules Dodd-Frank Enforcement Enforcement Actions First Amendment SEC

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