Ignore The First Conflict Minerals Filing

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Securities lawyers eagerly await the first (or the first few) new filings required by law to learn (and of course copy) from them.  So the first conflict minerals filing to hit Edgar last week was eagerly anticipated, and immediately over analyzed.

Broc Romanek at TheCorporateCounsel.net reported reader reaction ranging from “If this is the baseline, we are looking to be in good shape,” to “Good example of “what not to do”” to “This thing is totally bizarre.”

For the reasons set forth in this blog, we don’t think issuers will follow this as precedent.

So one lesson learned is never be the first to file anything new early.

We are hoping the second filing is more instructive.

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SEC

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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