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Securities Violations Disclosure Requirements Securities Exchange Act

Zelle  LLP

AI Update: New Lawsuit Highlights the Risks Of AI-Related Disclosures

Zelle LLP on

A recent lawsuit filed in the US District Court for the Southern District of New York—Sarria v. Telus International (Cda) Inc. et al., No. 1:25-cv-00889 (S.D.N.Y. Jan 30, 2025)—involves two distinct risks associated with...more

Cadwalader, Wickersham & Taft LLP

SEC Brings Suit Against Elon Musk for Failure to Report Twitter Ownership

On January 14, 2025, the U.S. Securities and Exchange Commission (the “SEC”) sued Elon Musk over his 2022 acquisition of Twitter, Inc. stock and alleged failure to timely disclose a 5% ownership stake in Twitter, as required...more

Cooley LLP

SEC files complaint against Elon Musk alleging violation of Section 13(d)

Cooley LLP on

On Tuesday, the SEC filed a complaint in the D.C. federal district court alleging that Elon Musk ignored the Section 13(d) beneficial ownership reporting deadline when, in March 2022, he acquired more than 5% of outstanding...more

BCLP

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

BCLP on

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

Hogan Lovells

SEC brings Regulation FD enforcement action for selective disclosure via social media

Hogan Lovells on

On September 26, the SEC announced that it had charged public company DraftKings Inc. with violating Regulation FD, or “Fair Disclosure,” under the Exchange Act. The SEC alleged that the company selectively disclosed...more

Bass, Berry & Sims PLC

Recyclable K-Cups: Investors Beware?

Bass, Berry & Sims PLC on

On September 10, the Securities and Exchange Commission (the Commission or SEC) charged Keurig Dr Pepper Inc. (Keurig) for making inaccurate statements about the recyclability of its K-Cup single-use beverage pods.  Without...more

BCLP

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

BCLP on

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

Sheppard Mullin Richter & Hampton LLP

Supreme Court Holds “Pure Omissions” Are Not Actionable Under Rule 10b-5(b)

In Macquarie Infrastructure Corp. v. Moab Partners, No. 22-1165, 2024 WL 1588706 (U.S. Apr. 12, 2024) (“MIC”), the United States Supreme Court (Sotomayor, J.) held unanimously that “pure omissions” in a Securities and...more

Morgan Lewis

Current Developments in SEC Enforcement for Public Companies 2024

Morgan Lewis on

The US Securities and Exchange Commission (SEC) continued its significant focus on public companies in 2023 with its enforcement and rulemaking programs, and this heightened level of attention will continue throughout 2024....more

Goodwin

Supreme Court to Decide Scope of Potential Liability Based on MD&A in Annual Reports

Goodwin on

On September 29, the Supreme Court agreed to hear a case that could significantly affect the scope of corporate liability under the securities laws. Lower courts disagree on whether the SEC-required “management’s discussion...more

Morgan Lewis

SEC Continues Focus on Executive Perquisites in Recent Action, Rewards Company’s Cooperation

Morgan Lewis on

A recent US Securities and Exchange Commission enforcement action demonstrates the Commission’s continued focus on executive perquisites and how cooperation with investigations may result in reduced—or no—civil monetary...more

Holland & Knight LLP

Risky Business: SEC Expands DCP Enforcement Using Company Risk Factors

Holland & Knight LLP on

Outside of the small circle of federal securities law nerds (we proudly proclaim our membership), the phrase "disclosure controls and procedures" (DCP) rarely garners much attention. However, a recent settled order issued by...more

Goodwin

SEC Signals Heightened Scrutiny Of Issuer/Analyst Communications And More Reg FD Enforcement

Goodwin on

On March 5, 2021, the U.S. Securities and Exchange Commission filed an enforcement action in the U.S. District Court for the Southern District of New York charging AT&T with repeated violations of Section 13 of the Securities...more

Mayer Brown Free Writings + Perspectives

SEC Enforcement Action for Misleading Pandemic Disclosure

The SEC has brought its first enforcement action against a public company relating to disclosure of the financial effect of the pandemic. The Cheesecake Factory Incorporated, without admitting or denying the SEC’s findings,...more

Cooley LLP

Blog: SEC brings first action for misleading disclosures regarding impact of COVID-19

Cooley LLP on

In its first action against a public company for misleading investors about the financial effects of the pandemic, the SEC has announced settled charges against The Cheesecake Factory. In mid-March, the company, which...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

Bass, Berry & Sims PLC

SEC Enforcement Activity – A Reminder Regarding the “Equal or Greater Prominence” Presentation Requirement of Item 10(e)

Bass, Berry & Sims PLC on

At the end of last year, in an enforcement action brought by the Division of Enforcement of the Securities and Exchange Commission (SEC) against ADT Inc. (ADT), reporting companies were reminded that the SEC continues to...more

Bass, Berry & Sims PLC

Recent SEC Enforcement Action Drives Home the Importance of Regulation FD Policies and Training

Bass, Berry & Sims PLC on

On August 20th, 2019, the SEC charged TherapeuticsMD Inc., a pharmaceutical company headquartered in Boca Raton, Florida, with violations of Regulation FD based on its sharing of material, nonpublic information with sell-side...more

Jones Day

SEC Enforcement in Financial Reporting and Disclosure: 2019 Mid-Year Update

Jones Day on

We are pleased to present our annual mid-year update on financial reporting and issuer disclosure enforcement activity for 2019. This White Paper primarily focuses on the U.S. Securities and Exchange Commission's enforcement...more

Sheppard Mullin Richter & Hampton LLP

“Airing Out the Denny Crane Room”: Recent SEC Action Emphasizes Need for Effective Disclosure Controls and Procedures for...

Last month, Energy XXI, Ltd. (“EXXI”), a publicly-traded oil and gas exploration company, saw its former Chief Executive Officer charged with various securities law violations by the Securities and Exchange Commission...more

King & Spalding

Eleventh Circuit Confirms that Issuers are not Required to Disclose Retention of Outside Promotional Firms

King & Spalding on

On December 15, 2016, the United States Court of Appeals for the Eleventh Circuit affirmed the dismissal of a securities class action against Galectin Therapeutics Inc., a Georgia-based biotechnology company. The suit...more

Carlton Fields

Dismissal for Drugmaker Affirmed: Galectin Had No Duty to Disclose Payments to Promoters

Carlton Fields on

In re: Galectin Therapeutics, Inc. Securities Litigation, No. 16-10324, 2016 WL 7240146, ____ , F2d ___ (11th Cir. Dec. 15, 2016). The Eleventh Circuit recently addressed the circumstances under which a public company...more

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