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Material Misstatements Securities and Exchange Commission (SEC)

A&O Shearman

Northern District Of California Grants Motion To Dismiss Securities Fraud Claim Against Ridesharing Company

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On January 16, 2025, Judge Trina L. Thompson of the United States District Court for the Northern District of California granted a motion to dismiss a securities action asserting claims under Sections 10(b) and 20(a) of the...more

Latham & Watkins LLP

SEC Targets Investment Advisers for Misstatements and Compliance Failures

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Three recent enforcement actions highlight the risks of failing to adhere to representations made to investors regarding ESG and biblically responsible investing strategies....more

Fenwick & West LLP

Is the SEC Cracking Down on Life Science Companies Misleading Investors?

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On December 3, the U.S. Securities and Exchange Commission settled charges against biotherapeutics company Kiromic BioPharma, Inc., its former CEO, and its former CFO for failing to disclose material information about...more

BCLP

The SEC is Watching: Four Companies Charged for Misleading Cyber Disclosures

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On October 22, 2024, the U.S. Securities and Exchange Commission (SEC) charged four publicly traded  technology companies with making materially misleading disclosures regarding cybersecurity risks and incidents (SEC press...more

A&O Shearman

The Second Circuit Revives Exchange Act Claims Against Outside Auditor, Finding Alleged Misstatements In Audit Certification To Be...

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On October 31, 2024, the United States Court of Appeals for the Second Circuit revived claims brought under Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and Rule 10b-5 against an outside auditor (the...more

A&O Shearman

Northern District Of Texas Dismisses Putative Securities Class Action For Failure To Establish Standing

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On October 24, 2024, Judge Jane J. Boyle of the United States District Court for the Northern District of Texas dismissed a putative securities class action alleging that a bond issuer (the “Company”) and certain of its...more

Vinson & Elkins LLP

SEC Eliminates ESG Task Force

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Over the last few months, the U.S. Securities and Exchange Commission (“SEC”) discretely disbanded the Climate and ESG Taskforce (“ESG Task Force”) of its Division of Enforcement. The move follows a wave of recent pushback...more

WilmerHale

SEC Takes Action Against Keurig for Allegedly Incomplete Disclosures Regarding Recyclability of K-Cups

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While the Securities and Exchange Commission’s (SEC) new climate-related disclosure rules remain stayed, the SEC has not abandoned its focus on sustainability-related issues. On September 10, 2024, the SEC charged Keurig Dr...more

A&O Shearman

Northern District of California Denies Motion To Dismiss Putative Class Action Based On Financial Services Company’s Alleged...

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On July 29, 2024, Judge Trina L. Thompson of the United States District Court for the Northern District of California denied a motion to dismiss a putative securities class action brought by investors against a financial...more

Holland & Knight LLP

Court in SolarWinds Case Blows Down SEC's Cyber Enforcement Authority

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The U.S. District Court for the Southern District of New York on July 18, 2024, dismissed most of the SEC's landmark cyber enforcement litigation against SolarWinds Corp. (SolarWinds or the Company) and the Company's Chief...more

A&O Shearman

United States Supreme Court Grants Certiorari To Consider When Already-Materialized Risks Must Be Disclosed

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On June 10, 2024, the United States Supreme Court granted certiorari to review a decision of the United States Court of Appeals for the Ninth Circuit that partially reinstated a putative class action asserting claims under...more

A&O Shearman

Sixth Circuit Affirms District Court’s Dismissal Of Putative Securities Class Action Against Car Insurance Company For Failure To...

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On April 29, 2024, the United States Court of Appeals for the Sixth Circuit affirmed the dismissal with prejudice of a putative class action asserting claims under the Sections 11, 12(a)(2), and 15 of the Securities Act of...more

A&O Shearman

Third Circuit Affirms District Court’s Dismissal Of Suit Against Vaccine Developer

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On March 21, 2024, the United States Court of Appeals for the Third Circuit affirmed the dismissal of a putative class action against a biopharmaceutical company (the “Company”) and certain of its officers under Sections...more

A&O Shearman

Southern District Of New York Narrows Claims In Putative Class Action Against China Based Real Estate Brokerage Company

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On February 26, 2024, Judge Gregory H. Woods of the United States District Court for the Southern District of New York narrowed claims in a putative class action asserting claims under the Securities Exchange Act of 1934 and...more

WilmerHale

SEC Brings Two More “AI Washing” Enforcement Actions Against Investment Advisers, Continuing Its Pursuit of Misstatements Related...

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On March 18, 2024, the Securities and Exchange Commission (SEC or the Commission) announced settled charges against two investment advisers, Delphia (USA) Inc. and Global Predictions, Inc., for making false and misleading...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: January 1, 2024

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges....more

A&O Shearman

Southern District Of New York Grants Motion To Dismiss Putative Securities Class Action Against Chinese Private-Sector Education...

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On December 6, 2023, Judge John G. Koeltl of the U.S. District Court for the Southern District of New York granted a motion to dismiss a putative securities class action brought against an operator of private schools in...more

White & Case LLP

The SEC’s Charges Against SolarWinds and its Chief Information Security Officer Provide Important Cybersecurity Lessons for Public...

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On October 30, 2023, the US Securities and Exchange Commission ("SEC") announced that it filed charges against SolarWinds Corp. ("SolarWinds" or the "Company") and its Chief Information Security Officer ("CISO") in connection...more

A&O Shearman

Nine Investment Firms Fined By The SEC For Marketing Rule Violations

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On September 11, 2023, the U.S. Securities and Exchange Commission announced settled enforcement actions against nine separate investment advisory firms for alleged marketing rule violations, assessing a total of $850,000 in...more

Katten Muchin Rosenman LLP

SEC Complaint Signals Aggressive Approach to Information Barriers Enforcement

On September 12, the Securities and Exchange Commission (SEC) filed a complaint in the Southern District of New York (SDNY) charging a large proprietary trading firm with making materially false and misleading statements and...more

Holland & Knight LLP

Prefabricated Facts: SEC Charges "Queen of Mobile Homes," Others for Years-Long Scheme

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A recent enforcement action from the Fort Worth Regional Office of the SEC reminds one of the agency's investor-protection mission and continued focus on those who deceive retail investors in the private offer and sale of...more

A&O Shearman

Fourth Circuit Affirms Dismissal Of Putative Class Action Under Section 14(a) For Failure To Adequately Allege Material Omissions...

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On June 1, 2023, the United States Court of Appeals for the Fourth Circuit affirmed the grant of summary judgment dismissing claims under Sections 14(a) of the Securities Exchange Act of 1934 against a financial company and...more

Holland & Hart LLP

Three Takeaways From Recent SEC Enforcement Case

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The Securities and Exchange Commission (SEC) just announced a settled enforcement matter involving a public company and its CFO.  (AP File No. 3-21438)  The case presents three important takeaways for companies and...more

Miller Canfield

Michigan Court of Appeals Broadens Potential Exposure to Securities Fraud by Issuers and Sellers of Debt Instruments in Michigan

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If your Michigan business issues promissory notes or other evidence of indebtedness, or if you purchase such debt instruments, it is important to understand whether those debt instruments could be considered “securities”...more

A&O Shearman

Brazilian Mining Company To Pay $55.9 Million To Settle SEC Charges Of Misleading ESG Disclosures

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On March 28, 2023, the Securities and Exchange Commission (“SEC”) submitted a settlement agreement (“settlement”) to the United States District Court of the Eastern District of New York with Brazilian mining company Vale S.A....more

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