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Cyan Inc v Beaver Cty Emps Ret Fund

Woodruff Sawyer

Securities Class Actions Report: Filings Against Public Companies Down for Second Year in a Row

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In 2021, 182 securities class actions were filed against issuers of stock listed on US exchanges. This statistic means that the total number of annual filings in 2021 was down 13% compared to 2020. As highlighted in our...more

Proskauer - Corporate Defense and Disputes

Supreme Court to Decide Whether Discovery Stays Apply to State-Court Securities Lawsuits This Fall

One of the most significant differences between bringing a securities lawsuit in state versus federal court is the application of the mandatory discovery stay set forth in the Private Securities Litigation Reform Act (the...more

Epstein Becker & Green

Supreme Court to Decide Whether the Automatic Stay of Discovery In Securities Act Claims Applies In State Court

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Three years ago, the United States Supreme Court confirmed in Cyan, Inc. v. Beaver County Employees Retirement Fund, 138 S. Ct. 1061 (2018) that claims brought under the Securities Act of 1933 (the “Securities Act”) are...more

Seyfarth Shaw LLP

In the Wake of the Pandora’s Box Opened by the Supreme Court’s Cyan Decision, Court to Address Discovery Stay Question in State...

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On July 2, 2021, the US Supreme Court granted the Petition for a Writ of Certiorari filed in Pivotal Software, to address one of the many questions stemming from the Court’s decision in Cyan, which permitted state courts to...more

Patterson Belknap Webb & Tyler LLP

First Department Issues First Ruling Dismissing Securities Act Claims Following the U.S. Supreme Court’s Cyan Decision

As New York commercial practitioners will recall, the U.S. Supreme Court in Cyan, Inc. v. Beaver Cty. Emps. Ret. Fund held that state and federal courts have concurrent jurisdiction over class actions alleging violations of...more

Kramer Levin Naftalis & Frankel LLP

Two Additional California Courts Dismiss Securities Act Claims in Favor of Federal Forum Selection Provisions

As previously discussed in our Sept. 10, 2020, client alert, in Wong v. Restoration Robotics, Inc., Case No. 18-CIV-02609 (Cal. Super. Ct. Sept. 1, 2020), the Superior Court of California for the County of San Mateo dismissed...more

Seyfarth Shaw LLP

Dropbox Becomes Third California Superior Court Decision To Enforce Delaware Corporations’ Federal Forum Provision For Securities...

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Three separate California Superior Courts have recently upheld federal forum provisions (“FFP”) in governing corporate documents to preclude state court actions under the Securities Act of 1933 (the “Securities Act”) (15...more

Seyfarth Shaw LLP

New York Appellate Division Decides First Securities Act Case Since Cyan

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On December 3, 2020, the New York State Appellate Division for the First Judicial Department dismissed an action alleging claims under the Securities Act of 1933 (the “Securities Act”) in Lyu v. Ruhnn Holdings Limited....more

Dechert LLP

State Courts Continue to Enforce Federal Forum Provisions

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Corporations started inserting federal forum provisions in light of the decision of the United States Supreme Court in Cyan, Inc. v. Beaver County Employees Retirement Fund, 138 S. Ct. 1061 (“Cyan”) (2018), which reaffirmed...more

Seyfarth Shaw LLP

California Superior Courts Enforce Delaware Corporations’ Federal Forum Provision For Securities Act Lawsuits

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In recent decisions, two separate California Superior Courts have upheld federal forum provisions (“FFP”) in governing corporate documents to preclude state court actions under the Securities Act of 1933 (the “Securities...more

Seyfarth Shaw LLP

California Superior Court Enforces Delaware Corporation’s Federal Forum Provision For Securities Act Lawsuits

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On September 1, 2020, the California Superior Court for San Mateo County granted Restoration Robotics, Inc. and certain individual defendants’ (collectively, “Restoration Robotics”) Motion for Reconsideration and Renewed...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways | Developments and Trends in Securities Litigation: Mid-Year Update 2020

On September 15, 2020, Skadden held the first program in our annual Securities Litigation and Regulatory Enforcement Update, titled “Developments and Trends in Securities Litigation: Mid-Year Update 2020.” ... ...The...more

Wiley Rein LLP

California Court Enforces Federal Forum Selection Provision For 1933 Act Claims

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A California court ruled that a forum selection provision in a Delaware company’s registration statement requiring that certain securities litigation be brought solely in federal court was enforceable.  Wong v. Restoration...more

Akin Gump Strauss Hauer & Feld LLP

Judge Rules California State Law Does Not Prohibit Federal Forum Provisions That Seek To Avoid Cyan’s Bar on Removal of Securities...

- California state court held that federal forum provisions for Securities Act claims are not illegal and may be used to sidestep the bar on removal of Securities Act claims following the United States Supreme Court’s ruling...more

Cooley LLP

Blog: Will the California courts enforce a Delaware exclusive federal forum provision?

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In Salzberg v. Sciabacucchi (pronounced Shabacookie), the Delaware Supreme Court unanimously held that charter provisions designating the federal courts as the exclusive forum for ’33 Act claims are “facially valid.” Given...more

Skadden, Arps, Slate, Meagher & Flom LLP

Delaware Supreme Court Upholds Validity of Provisions Designating Federal Courts as Exclusive Forum of 1933 Act Claims

In Salzberg v. Sciabacucchi, No. 346, 2019 (Del. Mar. 18, 2020), the Delaware Supreme Court upheld the validity of corporate charter provisions designating federal courts as the exclusive forum for the litigation of claims...more

Sullivan & Worcester

Delaware Supreme Court Upholds Federal Forum Selection Provisions - Delaware Corporations May Now Adopt Federal Forum Selection...

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On March 18, 2020, the Delaware Supreme Court reversed the Delaware Court of Chancery and held that Delaware corporations can adopt federal forum selection provisions for claims arising under the Securities Act of 1933 (the...more

BCLP

Federal Forum Provisions for Securities Act Claims Upheld by Delaware Supreme Court

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In the last two years, plaintiffs’ lawyers have increasingly been bringing lawsuits under the Securities Act of 1933 (“Securities Act”), such as claims relating to public offerings, in state rather than federal court. ...more

Pillsbury Winthrop Shaw Pittman LLP

Delaware Supreme Court: Delaware Corporations May Adopt Federal-Forum Provisions Requiring That Securities Act Claims Be Brought...

Ruling suggests a new means of stemming the flood tide of state-court Securities Act claims that followed the U.S. Supreme Court’s Cyan decision in 2018. But uncertainty lingers as to whether post-IPO public companies can...more

White and Williams LLP

Delaware Supreme Court Upholds Federal Forum Selection for Securities Act Claims

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On Wednesday, March 18, 2020, the Delaware Supreme Court overturned a Chancery Court decision that had prohibited Delaware corporations from adopting federal forum selection provisions for actions arising under the federal...more

Troutman Pepper Locke

Exclusive Federal Forum Selection Provisions for Securities Act Claims Held to be Valid in Delaware

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On March 18, in Salzberg v. Sciabacucchi, No. 346, 2019, the Delaware Supreme Court held that Delaware corporations may validly adopt forum selection provisions requiring that all claims arising under the federal Securities...more

Orrick, Herrington & Sutcliffe LLP

Reversing Chancery Court, Delaware Supreme Court Holds That Federal Forum Provisions in Delaware Corporate Charters Are Valid

On March 18, 2020, the Supreme Court of Delaware held that the “relatively recent phenomenon” of federal forum provisions (“FFPs”) in Delaware companies’ charters, which mandate that stockholder claims arising under the...more

Ballard Spahr LLP

Delaware Supreme Court Revives Charter Provision Requiring Securities Act Claims Be Brought in Federal Court

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The Delaware Supreme Court, in reversing a Delaware Court of Chancery decision, upheld a corporate charter provision requiring stockholders bring claims arising under the Securities Act of 1933, as amended (the 1933 Act), in...more

Stinson - Corporate & Securities Law Blog

Delaware Supreme Court Finds Federal Forum Selection Provisions are Facially Valid

The Delaware Supreme Court held federal-forum provisions, or FFPs, in charters of Delaware corporations are facially valid in Salzberg et al v. Sciabacucchi.  The FFPs at issue generally provided that the federal district...more

WilmerHale

Delaware Supreme Court Upholds Validity of Federal Forum Provisions in Landmark Ruling

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On March 18, 2020, in a landmark ruling in Salzberg v. Sciabacucchi, No. 346, 2019 (Del. Mar. 18, 2020), the Delaware Supreme Court upheld the validity of provisions of corporate articles of incorporation that require...more

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