The SEC’s conflict minerals rules have withstood judicial challenge — so far. On July 23, 2013, the U.S. District Court for the District of Columbia rejected the summary judgment motion of the plaintiffs challenging the conflict minerals rules and upheld the cross-motion by the SEC and an intervenor for summary judgment. The plaintiffs have not announced whether they plan to appeal. While the decision does not necessarily settle the issue, it appears increasingly likely that there will not be judicial relief between now and the end of 2013 or even the deadline for filing the first Form SD, which is May 31, 2014 with respect to calendar year 2013. Accordingly, we recommend that companies continue the process of gathering the information necessary to comply with these new disclosure requirements.