News & Analysis as of

Failure To Disclose Disclosure Requirements Securities Exchange Act

A&O Shearman

Eastern District Of Wisconsin Dismisses Class Action Against Energy Products Company For Failure To Allege Falsity, Scienter, And...

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On February 7, 2025, Judge Brett H. Ludwig of the United States District Court for the Eastern District of Wisconsin dismissed a putative class action alleging that an energy product sales company (the “Company”) and its...more

BCLP

Perk Redux - Yet Another Company Stumbles Over SEC Executive Compensation Rules

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On December 17, 2024, the SEC announced settled charges against Express, Inc. for failing to disclose perks paid to its then CEO, including personal use of airplanes. Without admitting or denying the SEC’s findings,...more

BCLP

Why Can’t We Be Friends?

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Recently, the SEC announced settled charges against a former chairman/CEO and director of Church & Dwight Co. Inc., for violating proxy disclosure rules by standing for election as an independent director without informing...more

BCLP

ICAHN Settles With SEC for Failures to Disclose Key Details of Margin Loan Stock Pledges - Teaching Moment for Directors and...

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On August, 19, 2024, the SEC announced settled charges against Carl C. Icahn and his publicly traded company, Icahn Enterprises L.P. (IEP), for failing to disclose information relating to Icahn’s pledges of IEP securities –...more

Vinson & Elkins LLP

Not Lovin’ It: SEC’s Settlement With McDonald’s Former CEO Highlights Continued Focus on Executive-Related Disclosures

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On January 9, 2023, the Securities and Exchange Commission (“SEC”) issued a cease-and-desist order (the “Order”)1 charging McDonald’s Corporation (“McDonald’s”) and its ex-CEO, Stephen Easterbrook, with multiple disclosure...more

Cooley LLP

Blog: SEC charges company for failure to disclose material trends

Cooley LLP on

The SEC has just settled an action against Diageo PLC, a producer of liquor, wine and beer, for failure to disclose known trends and uncertainties. Diageo’s omission resulted in materially misleading disclosures regarding...more

Faegre Drinker Biddle & Reath LLP

SEC: Here Is When Loss Contingencies Must Be Disclosed and Reserved

When confronted with government inquiries, public companies commonly grapple with the issue of when events have escalated to the point that they are subject to disclosure obligations—or, further yet, require recognition as a...more

Cooley LLP

Blog: Failure to disclose “revenue management scheme” leads to SEC action

Cooley LLP on

In this Enforcement Order, the SEC described a “revenue management scheme” orchestrated by the respondent, Marvell Technology Group, and the imposition on Marvell of a $5.5 million penalty and cease-and-desist order—not...more

A&O Shearman

Southern District Of Florida Dismisses Putative Class Action Against Beverage Company For Failure To Adequately Allege...

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On August 29, 2019, Judge K. Michael Moore of the United States District Court for the Southern District of Florida dismissed a putative class action against National Beverage Corporation and certain of its officers asserting...more

Jones Day

SEC Announces Yahoo Will Pay $35 Million for Failure to Disclose Data Security Incident

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The Situation: The SEC accused Altaba Inc., then known as Yahoo! Inc., of misleading investors by failing to disclose a major data breach orchestrated by Russian hackers. The Result: Altaba has agreed to pay $35 million to...more

Poyner Spruill LLP

The SEC Fines Yahoo for Alleged Failure to Disclose CyberBreach

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The Securities and Exchange Commission (SEC) has undertaken its first enforcement action in connection with a public company’s failure to timely disclose cyber-issues. Last month, Altaba Inc., the former Yahoo! Inc. (Yahoo!),...more

Eversheds Sutherland (US) LLP

It’s a material world - why the SEC’s Yahoo! penalty really matters

In the aftermath of the April 24, 2018, Securities and Exchange Commission (SEC) statement announcing its penalty against Altaba Inc., formerly Yahoo! Inc. (Yahoo!), for failing to timely report a massive data breach,...more

Williams Mullen

Yahoo! Settlement Affirms SEC's Focus on Cybersecurity Disclosures

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In late April 2018, the SEC and Altaba (formerly known as Yahoo!) agreed to a $35 million penalty to settle charges that Yahoo! misled investors by failing to disclose to investors its December 2014 data breach in which...more

Arnall Golden Gregory LLP

Altaba (Yahoo) Agrees to Pay $35 million Penalty as SEC Continues to Emphasize Importance of Cybersecurity Data Breach Disclosures

On April 24, 2018, the Securities and Exchange Commission (the “SEC”) announced that Altaba Inc. (f/k/a Yahoo! Inc.) agreed to pay a $35 million penalty relating to charges that it misled investors with respect to disclosure...more

Troutman Pepper Locke

An Unasserted Lesson of the SEC’s Yahoo Cyberbreach Enforcement Action

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Much has already been written about the SEC’s enforcement action involving Yahoo’s failure to adequately disclose a cyberbreach.1 I am writing about something that the SEC’s announcement and order did not address and...more

Dorsey & Whitney LLP

Failure to Disclose Leads to $35 Million Penalty in the Yahoo! Cybersecurity Breach

Dorsey & Whitney LLP on

The Securities and Exchange Commission (the “SEC”) announced Tuesday that Altaba, the entity formerly known as Yahoo! Inc., has agreed to pay a $35 million penalty to settle charges that it misled investors by failing to...more

Harris Beach Murtha PLLC

Yahoo Settles Claims by SEC regarding 2014 Data Breach

Yesterday, the Securities and Exchange Commission (SEC) announced an important administrative settlement with Altaba (Yahoo) related to the company’s failure to disclose a major security breach to its users and investors....more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of Compensation-Related Litigation on Public Companies

Compensation-related litigation and threats of litigation continued to significantly impact public companies in 2017. These companies should be mindful of issues that were raised in recent litigation: proxy disclosure,...more

A&O Shearman

Third Circuit Affirms Dismissal Of Putative Securities Class Action, Finds No Duty To Disclose An Event Named In A Risk Disclosure...

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On August 23, 2017, the United States Circuit Court of Appeals for the Third Circuit affirmed a district court decision dismissing a putative class action against Globus Medical, Inc. (“Globus” or the “Company”), a medical...more

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