On April 14, 2014, the U.S. Court of Appeals for the D.C. Circuit issued its long-awaited decision in the challenge to the SEC’s conflict minerals disclosure rule filed by the National Association of Manufacturers (“NAM”) and other industry groups, giving the challengers a partial victory on First Amendment grounds. NAM had challenged several aspects of the SEC’s rules as violating the Administrative Procedure Act (“APA”), the Exchange Act, and the First Amendment. The Court rejected the APA and Exchange Act challenges to the rules, but by a 2-1 margin found that certain aspects of the SEC’s rules violate the First Amendment by compelling issuers to engage in stigmatizing commercial speech about their own products. Whether that partial victory will result in meaningful changes to the SEC’s conflict minerals reporting regime remains to be determined, as the Court’s First Amendment ruling focused on the rule’s requirement that issuers use the particular descriptor “not found to be ‘DRC conflict free’” in describing their own products, leading to potential debate as to whether the constitutional issues with the rule are limited to those particular “magic words,” or whether the public reporting aspect of the rule requires a broader reconsideration and adjustment. This Legal News Alert provides a brief summary of the Court’s decision, as well as preliminary thoughts on how this might impact conflict minerals compliance issues for issuers and companies in their supply chains.