Forever changing the landscape of securities cases against foreign corporations, on June 25, 2010, the U.S. Supreme Court issued its decision in Morrison v. Nat'l Australia Bank Ltd. Morrison sounds a death knell for the conducts test and effects test, which originated from the Second Circuit's analysis of the extraterritorial application of the Securities Exchange Act. Writing for the majority decision was Justices Scalia, Roberts, Kennedy, Thomas, and Alito. The issue presented to the U.S. Supreme Court was whether §10(b) of the Securities Exchange Act had extraterritorial application.

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