CFTC Adopts Final Anti-Manipulation and Anti-Fraud Rules & Begins Final Rulemaking Phase Implementing Dodd-Frank
|
|
- Bruce Holmes
- 5 years ago
- Views:
Transcription
1 CFTC Adopts Final Anti-Manipulation and Anti-Fraud Rules & Begins Final Rulemaking Phase Implementing Dodd-Frank by Peggy A. Heeg, Michael Loesch, and Lui Chambers On July 7, 2011, the Commodity Futures Trading Commission ( CFTC ) approved five rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act or Dodd-Frank ). In adopting the first major rules under Dodd-Frank, the Commission launched an intense rulemaking period in which approximately 50 final rules are expected to be finalized during regular Commission meetings held over the coming months. Most significantly, during the July 7 th CFTC meeting, the Commission unanimously approved new anti-fraud and anti-manipulation rules implementing key provisions of Dodd-Frank. The rules, which will be effective 30 days after publication in the Federal Register, grant the Commission significant new authority to pursue fraud and manipulation in the futures, swaps and commodities markets. As of the preparation of this briefing, the final rules have not yet been published in the Federal Register. In addition to the anti-manipulation rules, the CFTC finalized four Dodd-Frank rules addressing: (i) the definition of agricultural commodity; (ii) business affiliate marketing and disposal of consumer information; (iii) privacy of consumer financial information; and (iv) large trader reporting for physical commodity swaps. Rules Prohibiting Fraud and Fraud-Based Market Manipulation The final anti-fraud and anti-manipulation rules implement key provisions of Dodd-Frank Section 753, which provides the Commission with significant new enforcement tools to pursue fraud and manipulation in futures, swaps and physical commodities. 1 Although the final rules adopt regulations that are virtually identical to those proposed by the Commission in its proposed rules, 2 the preamble to the rules illustrates the breadth and significance of the Commission s new authority. Despite the lack of specificity as to prohibited conduct, the views expressed during the Commission s meeting, coupled with the flexible standard adopted, illustrate the significance of the Commission s new enforcement powers. 1 Among other things, Section 753 of Dodd-Frank amends Section 6(c) and Section 22(a) of the CEA, which in turn are codified at 7 U.S.C. 9, 15 and 7 U.S.C. 25, respectively. 2 See Prohibition of Market Manipulation, 75 Fed. Reg. 67,657 (Nov. 3, 2010). The sole change to the final regulatory text was the addition of the word inaccurate to Rule 180.1(a)(4), which was made simply to conform the rule to the terms of the related statutory provision (CEA Section 6(c)(1)(C)). For a detailed discussion of the manipulation rules as originally proposed, please see our prior Financial Reform briefing entitled, CFTC s 3rd Series of Proposed Rules Under Dodd-Frank: Proposed Manipulation Rules and Disruptive Practices Concept Release Issued, available at 1
2 Final Rule Under CEA Section 6(c)(1) Dodd-Frank Section 753 amended subsection 6(c)(1) of the Commodity Exchange Act ( CEA ) by adding a fraud-based manipulation provision modeled on section 10(b) of the Securities Exchange Act of In implementing Section 753, the CFTC adopted a new final regulation, to be promulgated at 17 CFR 180.1, which is based on SEC Rule 10b-5. Specifically, new Rule makes it unlawful to: (i) employ any manipulative device, scheme or artifice to defraud; (ii) make or attempt to make any untrue or misleading statement of a material fact or to omit to state a material fact; (iii) engage in any act, practice, or course of business, which operates or would operate as a fraud or deceit upon any person; or (iv) deliver a false or misleading or inaccurate report concerning crop or market information. In modeling the final rule on SEC Rule 10b-5, the Commission stated that it will be guided, but not controlled, by the judicial precedent applying comparable language in Rule 10b-5. In doing so, the Commission provided that it intends to interpret the rule not technically and restrictively, but flexibly to effectuate its remedial purposes and notes that proof of a market or price affect is not required. Lower Scienter Threshold Although the CFTC has historically been vested with broad powers to prosecute market manipulation, specific intent to manipulate the market was required. In the past, the CFTC has struggled to prove intent in manipulation or even attempted manipulation cases. While Dodd-Frank does not specifically establish a recklessness standard, final Rule adopts a recklessness scienter standard consistent with precedent interpreting SEC Rule 10b-5. The new rule thus creates a lower scienter threshold and prohibits fraud and fraud-based manipulative devices employed intentionally or recklessly, regardless of whether the suspect conduct was intended to create an artificial price. Specifically, the Commission clarified that a showing of recklessness is, at a minimum, necessary to prove the scienter element of final Rule In doing so, the rule closes a perceived regulatory gap in the Commission s antimanipulation enforcement activities and brings the CFTC s authority in line with the enforcement powers of the FERC, the FTC and the SEC. The Commission defines recklessness as an act or omission that departs so far from the standards of ordinary care that it is very difficult to believe the actor was not aware of what he or she was doing. While the Commission has not provided any specific examples of the type of trading behavior that would be captured by the reckless scienter element, it has equated the new scienter standard to the corresponding requirement under securities laws, and further declared that it will apply a facts and circumstances test to each case it brings under the new enforcement provision. The Commission affirmed, however, that the reckless standard of final Rule will not capture inadvertent mistakes or negligence. Nonetheless, by shifting from the affirmative intent requirement of the past, the CFTC is moving to an enforcement environment where inadequate controls, lax supervision, or flawed compliance programs could be sufficient to establish recklessness under the new anti-fraud rule. 2
3 Disclosure and Trading Based on Material Nonpublic Information New CEA Section 6(c)(1) provides that no rule or regulation promulgated by the Commission shall require any person to disclose certain nonpublic information, including information that may be material to the price of a commodity transaction. Consistent with this statutory requirement, the final rules do not impose affirmative new duties on market participants (such as disclosure, diligence or inquiry requirements). The Commission acknowledged that it is not a violation of final Rule to withhold information that a market participant lawfully possesses about market conditions and that, absent a pre-existing duty to disclose, silence is not deceptive under the new rule. Disclosure of certain nonpublic information is required, however, where such disclosure is necessary to make any statements made not misleading. The Commission specifically emphasized that fraud by partial-omission or half-truths could violate final Rule 180.1, if warranted under the facts and circumstances. In addition, the Commission emphasized that it interprets new Section 6(c)(1) and final Rule to prohibit trading on the basis of material nonpublic information to the extent such information was obtained in breach of a pre-existing duty. The duty breached may originate from another law or rule, agreement, understanding, or some other source. According to the Commission, the new rule also prohibits any trading on the basis of material nonpublic information obtained fraudulently or through deceptive practices. In Connection With Requirement New CEA Section 6(c)(1) and final Rule provide that the fraud or manipulation must be in connection with a swap, commodity or future. In addressing the in connection with requirement, the Commission stated that, while the scope is not limitless, it will look to securities law precedent and interpret the term broadly, not technically or restrictively. Accordingly, the prohibitions of Section 6(c)(1) and final Rule will reach all manipulative or deceptive conduct in connection with the purchase, sale, solicitation, execution, pendency, or termination of any swap, commodity, or future. This reach includes all of the payment and other obligations arising under a swap. The Commission has focused much of its enforcement efforts in recent years on cross-market manipulations, that is, when alleged manipulative activity in one market is used to benefit positions held in another market. Significantly, in adopting the final rule, the Commission also emphasized that it will apply final Rule to the fullest extent allowed by law when determining whether conduct in one market meets the in connection with requirement and is sufficiently related to activity subject to the Commission s jurisdiction. Relationship to Existing Anti-Manipulation Authority The Commission affirmed that its existing market manipulation and false reporting authority under CEA Section 9(a)(2) is not impacted by the final rules and will continue to serve as an additional device to combat market manipulation. Final Rule 180.1(c) specifically provides that [n]othing 3
4 in this section shall affect, or be construed to affect, the applicability of Commodity Exchange Act section 9(a)(2). The Commission s historic anti-manipulation authority under CEA Section 9(a)(2) differs from the new authority under CEA Section 6(c)(1) in that it not only requires a higher scienter standard, but also requires price manipulation or an effect on prices to be proven, while revised CEA Section 6(c)(1) and Rule only require an intentional or reckless mental state and do not require proof of price or market impact. Manipulation by False Reporting & Good-Faith Mistakes New CEA Section 6(c)(1)(A) includes within the Commission s anti-manipulation authority a prohibition of manipulation by false reporting, which prohibits, among other things, knowingly or recklessly delivering a false or misleading or inaccurate report concerning crop or market information. New CEA Section 6(c)(1)(C), however, provides an exception to this prohibition for good faith mistakes in transmitting false or misleading or inaccurate information to a price reporting service. The Commission included a good faith exception in final Rule but declined to expand the exception beyond the statutory language relating to the mistaken reporting of information to a price reporting service. Final Rule Under CEA Section 6(c)(3) Other Manipulation Dodd-Frank Section 753 also amends CEA Section 6(c) by adding new subsection (c)(3), which prohibits manipulation and attempted manipulation of the price for swaps, commodities, and futures contracts. The final rule implementing this price manipulation provision, Rule 180.2, mirrors the Dodd-Frank statutory language and makes it unlawful for any person, directly or indirectly, to manipulate or attempt to manipulate the price of any swap, or of any commodity in interstate commerce, or for future delivery on or subject to the rules of any registered entity. The Commission affirmed that in applying Rule it would follow the Commission s traditional four-part test for manipulation that has developed through case law under CEA Section 9(a)(2), which requires that the Commission establish that: (i) the accused had the ability to influence market prices; (ii) the accused specifically intended to create artificial market prices; (iii) an artificial price existed; and (iv) the accused caused the artificial prices. The Commission confirmed that recklessness will not be sufficient to meet the scienter requirement under new CEA Section 6(c)(3) and final Rule The Commission also emphasized that it will interpret the term indirectly in Rule to include circumstances where a person uses a third party to engage in conduct designed to manipulate. As an example, the Commission indicated that it will not be a defense to a manipulation charge under CEA Section 6(c)(3) that a trader utilizes an executing broker to execute suspect trades and does not execute the trades himself. 4
5 Conclusion During the Commission s meeting, Commissioner O Malia expressed concern that the proposed final manipulation rules did not provide market participants with sufficient clear and straight-forward guidance to enable them to correctly identify their legal obligations and what constitutes prohibited conduct. Commissioner Sommers also noted that neither the CEA amendments to Section 6(c) nor the final rules provided any indication under what circumstances the Commission would prosecute: (i) false reporting under Section 9(a)(2) as opposed to the new false reporting prohibition under new Section 6(c)(1)(A) and Regulation 180.1(a)(4); or (ii) manipulation under Section 9(a)(2) as opposed to the new manipulation prohibition under new Section 6(c)(3) and Regulation Notwithstanding these expressed concerns, the final rules were adopted unanimously. Enforcement Director David Meister emphasized during the Commission s open meeting that the new anti-fraud and anti-manipulation provisions, and the final rules thereunder, will be a priority for the Commission s Enforcement Division in conducting investigations. Chairman Gensler added that the new rules will broaden the types of cases the CFTC can pursue and will improve its chances of successful prosecution. With a lower, recklessness scienter standard and application to all manners of fraudulent and deceptive conduct, these new authorities, once effective, will provide the Commission with substantial tools to aggressively investigate and prosecute fraud-based market misconduct. Accordingly, market participants should immediately consider taking steps to educate traders and other relevant personnel on prohibited trading practices and the CFTC s new enforcement powers. The above is based on the discussion during the CFTC s public meeting and related materials published by the CFTC, available at cftcdoddfrank html. Peggy Heeg Michael Loesch Lui Chambers Attorney Advertising 07/11 NF Copyright 2011 Fulbright & Jaworski L.L.P. All Rights Reserved
Sec. 202(a)(1)(C). Disclosure of Negative Risk Determinations about Financial Company.
Criminal Provisions in the Dodd Frank Wall Street Reform & Consumer Protection Act 1 S. 3217 introduced by Senator Dodd (D CT) H.R. 4173 introduced by Barney Frank (D MASS) (all references herein are to
More informationA Short Guide to the Prosecution of Market Manipulation in the Energy Industry: CFTC, FERC, and FTC
JULY 2008, RELEASE TWO A Short Guide to the Prosecution of Market Manipulation in the Energy Industry: CFTC, FERC, and FTC Layne Kruse and Amy Garzon Fulbright & Jaworski L.L.P. A Short Guide to the Prosecution
More informationCriminal Provisions and Implications of the Dodd-Frank Act
GOVERNMENT ENFORCEMENT AND CORPORATE COMPLIANCE Securities- Related Crime By Juliane Balliro Criminal Provisions and Implications of the Dodd-Frank Act While Congress has virtually ensured that investigations
More informationUS legal and regulatory developments Prohibition on energy market manipulation
US legal and regulatory developments Prohibition on energy market manipulation Ian Cuillerier Hunton & Williams, 200 Park Avenue, 52nd Floor, New York, NY 10166-0136, USA. Tel. +1 212 309 1230; Fax. +1
More informationFTC's Proposed Petroleum Market Manipulation Rule And Market Manipulation Workshop
FTC's Proposed Petroleum Market Manipulation Rule And Market Manipulation Workshop Washington, DC November 19, 2008 On November 6, 2008, the Federal Trade Commission ( FTC ) held a workshop in which its
More informationSecurities and Exchange Commission v. Ingles Markets, Inc. Doc. 6 Case 1:06-cv LHT-DLH Document 6 Filed 04/28/2006 Page 1 of 8
Securities and Exchange Commission v. Ingles Markets, Inc. Doc. 6 Case 1:06-cv-00136-LHT-DLH Document 6 Filed 04/28/2006 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA
More informationCase 3:16-cv EMC Document 311 Filed 02/12/18 Page 1 of 7
Case :-cv-0-emc Document Filed 0// Page of JINA L. CHOI (N.Y. Bar No. ) JOHN S. YUN (Cal. Bar No. 0) yunj@sec.gov MARC D. KATZ (Cal. Bar No. ) katzma@sec.gov JESSICA W. CHAN (Cal. Bar No. ) chanjes@sec.gov
More informationThe Challenges For CEA Price Manipulation Plaintiffs
The Challenges For CEA Price Manipulation Plaintiffs By Mark Young, Jonathan Marcus, Gary Rubin and Theodore Kneller, Skadden Arps Slate Meagher & Flom LLP Law360, New York (April 26, 2017, 5:23 PM EDT)
More informationUNITED STATES DISTRICT COURT DISTRICT OF NEVADA ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. Plaintiff, DRAFT. Defendants. CLASS ACTION COMPLAINT
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, WYNN RESORTS LIMITED, STEPHEN A. WYNN, and CRAIG SCOTT BILLINGS, Defendants.
More informationEBERHARD SCHONEBURG, ) SECURITIES LAWS
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION ) AND ON BEHALF OF ALL OTHERS ) CASE No.: SIMILARLY SITUATED, ) 7 ) 8 Plaintiff, ) CLASS ACTION vs. ) COMPLAINT 9 ) FOR VIOLATIONS
More informationHigh Court Extends Reach Of Securities Fraud Rule 10b-5
Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com High Court Extends Reach Of Securities Fraud
More informationUNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA. Case No.: Plaintiff, Defendants
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF, Individually and on Behalf of All Others Similarly Situated, Case No.: vs. Plaintiff, CLASS ACTION COMPLAINT FOR VIOLATION OF THE
More informationSec. 9 SECURITIES EXCHANGE ACT OF 1934
85 SECURITIES EXCHANGE ACT OF 1934 Sec. 9 1998, 112 Stat. 3236; Pub. L. 106-554, Sec. 1(a)(5) [title II, Sec. 206(b)], Dec. 21, 2000, 114 Stat. 2763, 2763A-429; Pub. L. 111-203, title IX, Sec. 929, July
More informationUNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA. CASE No.: COMPLAINT
Ira M. Press KIRBY McINERNEY LLP 825 Third Avenue, 16th Floor New York, NY 10022 Telephone: (212) 371-6600 Facsimile: (212) 751-2540 Email: ipress@kmllp.com Counsel for Plaintiff UNITED STATES DISTRICT
More informationUNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY. No.
UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY PLAINTIFF, In His Behalf and on Behalf of All Others Similarly Situated, v. Plaintiff, COGNIZANT TECHNOLOGY SOLUTIONS CORPORATION, FRANCISCO D SOUZA,
More informationUNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. Plaintiff, DRAFT. Defendants. CLASS ACTION COMPLAINT
UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, BRUKER CORPORATION, FRANK H. LAUKIEN, and ANTHONY L. MATTACCHIONE, Defendants.
More informationUNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ALAN GRABISCH, Individually and on Behalf of All Others Similarly Situated, Plaintiff,
Case :-cv-0 Document Filed 0// Page of Page ID #: 0 SCOTT+SCOTT ATTORNEYS AT LAW LLP JOHN T. JASNOCH (CA 0) jjasnoch@scott-scott.com 00 W. Broadway, Suite 00 San Diego, CA 0 Telephone: () - Facsimile:
More informationmuia'aiena ED) wnrn 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA
2:15cv-05921DSF-FFM Document 1 fled 08/05/15 Page 1 of 17 Page ID #:1 1 Laurence M. Rosen, Esq. (SBN 219683) 2 THE ROSEN LAW FIRM, P.A. 355 South Grand Avenue, Suite 2450 3 Los Angeles, CA 90071 4 Telephone:
More informationDIFC LAW No.12 of 2004
---------------------------------------------------------------------------------------------- MARKETS LAW DIFC LAW No.12 of 2004 ----------------------------------------------------------------------------------------------
More informationCase 1:05-cv MSK -CBS Document 843 Filed 01/21/11 USDC Colorado Page 1 of 7
Case 1:05-cv-00480-MSK -CBS Document 843 Filed 01/21/11 USDC Colorado Page 1 of 7 Civil Action No. 05-cv-00480-MSK-CBS IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Honorable Marcia
More informationNinth Circuit Establishes Pleading Requirements for Alleging Scheme Liability Under 10(b) and Rule 10b-5(a) of the Securities Exchange Act of 1934
July 24, 2006 EIGHTY PINE STREET NEW YORK, NEW YORK 10005-1702 TELEPHONE: (212) 701-3000 FACSIMILE: (212) 269-5420 This memorandum is for general information purposes only and does not represent our legal
More informationCase 2:10-cv PA -PJW Document 1 Filed 08/17/10 Page 1 of 26 Page ID #:10
Case 2:10-cv-06128-PA -PJW Document 1 Filed 08/17/10 Page 1 of 26 Page ID #:10 I EDWARD J. MCINTYRE [SBN 804021 emcintyyre((^^swsslaw.com 2 RICHART&"E. MCCARTHY [SBN 1060501 rmccarthswsslaw.com y 3 SOLOM6
More informationCase No. upon information and belief, except as to those allegations concerning Plaintiff, which are
Case 1:15-cv-09011-GBD Document 1 Filed 11/17/15 Page 1 of 16 THE ROSEN LAW FIRM, P.A. Phillip Kim, Esq. (PK 9384) Laurence M. Rosen, Esq. (LR 5733) 275 Madison Avenue, 34th Floor New York, New York 10016
More informationUNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS
Case 1:14-cv-13180-RGS Document 1 Filed 07/31/14 Page 1 of 18 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS Battle Construction Co., Inc., individually and on behalf of all others similarly situated,
More informationUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. Plaintiff, DRAFT. Defendants.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, LULULEMON ATHLETICA, INC., LAURENT POTDEVIN and STUART C. HASELDEN,
More informationCase 1:15-cv JMS-MJD Document 177 Filed 06/30/17 Page 1 of 6 PageID #: 891
Case 1:15-cv-00758-JMS-MJD Document 177 Filed 06/30/17 Page 1 of 6 PageID #: 891 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION UNITED STATES SECURITIES AND EXCHANGE COMMISSION,
More informationUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. ) ) ) Case No. ) ) ) ) CLASS ACTION COMPLAINT ) ) ) JURY TRIAL DEMANDED ) ) ) ) Plaintiff,
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK PLAINTIFF, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, TRIVAGO N.V., ROLF SCHRÖMGENS and AXEL HEFER, Defendants.
More informationUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION SECURITIES AND EXCHANGE COMMISSION, v. Plaintiff, CAROLYNE SUSAN JOHNSON, Defendant. Civ. Action No. 1:18-cv-00364 FINAL JUDGMENT
More informationUNITED STATES DISTRICT COURT DISTRICT OF COLORADO ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. Plaintiff, Defendants. CLASS ACTION COMPLAINT
UNITED STATES DISTRICT COURT DISTRICT OF COLORADO, Individually and On Behalf of All Others Similarly Situated, RIOT BLOCKCHAIN, INC., JOHN R. O ROURKE III, and JEFFREY G. McGONEGAL, v. Plaintiff, Defendants.
More informationCase: 1:12-cv CAB Doc #: 4 Filed: 07/31/12 1 of 8. PageID #: 84 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO.
Case: 1:12-cv-01954-CAB Doc #: 4 Filed: 07/31/12 1 of 8. PageID #: 84 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO SECURITIES AND EXCHANGE COMMISSION, Plaintiff, MICHAEL A. BODANZA and
More informationCase 3:18-cv Document 1 Filed 08/10/18 Page 1 of 14
Case :-cv-0 Document Filed 0/0/ Page of 0 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA WILLIAM CHAMBERLAIN, on behalf of himself and all other similarly situated v. TESLA INC., and ELON
More informationUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. Plaintiff, DRAFT. Defendants.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, GRUPO TELEVISA, S.A.B., EMILIO FERNANDO AZCÁRRAGA JEAN and SALVI RAFAEL
More informationUNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA. Plaintiff, I COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS.
Case 3:-cv-00980-SI Document Filed 02/29/ Page of 2 3 4 8 9 0 4 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case No. 2 22 2 2 vs. HORTONWORKS, INC., ROBERT G. BEARDEN, and SCOTT J. DAVIDSON,
More information- 1 - Class Action Complaint for Violation of the Federal Securities Laws
1 1 1 1 Laurence M. Rosen, Esq. (SBN ) THE ROSEN LAW FIRM, P.A. South Grand Avenue, Suite 0 Los Angeles, CA 001 Telephone: () - Facsimile: () - Email: lrosen@rosenlegal.com Counsel for Plaintiff UNITED
More informationAccountants Liability. An accountant may be liable under common law due to negligence or fraud.
Accountants Liability Liability under Common Law An accountant may be liable under common law due to negligence or fraud. Negligence A loss due to negligence occurs when an accountant violates the duty
More informationA DEVELOPMENT IN INSIDER TRADING LAW IN THE UNITED STATES: A CASE NOTE ON CHIARELLA v. UNITED STATES DOUGLAS W. HAWES *
Journal of Comparative Corporate Law and Securities Regulation 3 (1981) 193-197 193 North-Holland Publishing Company A DEVELOPMENT IN INSIDER TRADING LAW IN THE UNITED STATES: A CASE NOTE ON CHIARELLA
More information3. USAT is a provider of cashless, micro-transactions an
Case 2:09-cv-03899-JD Document 1 Filed 08/27/2009 Page 1 of 7 JD UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA USA TECHNOLOGIES, INC. 100 Deerfield Lane AUG 272009 Suite 140 MICH!~~UI\jZ,
More informationCase 3:16-cv Document 1 Filed 11/11/16 Page 1 of 16 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA. Case No. Plaintiff, Defendants
Case :-cv-00 Document Filed // Page of POMERANTZ LLP Jennifer Pafiti (SBN 0) North Camden Drive Beverly Hills, CA 0 Telephone: () - E-mail: jpafiti@pomlaw.com - additional counsel on signature page - UNITED
More informationUNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA : : : : : : : : : : : : : :
Case -cv-0 Document Filed // Page of Page ID # 0 0 Jennifer Pafiti (SBN 0) POMERANTZ LLP North Camden Drive Beverly Hills, CA 00 Telephone (0) -0 E-mail jpafiti@pomlaw.com POMERANTZ LLP Jeremy A. Lieberman
More informationNinth Circuit Holds That Section 14(e) of the Exchange Act Requires a Showing of Mere Negligence, Not Scienter
Ninth Circuit Holds That Section 14(e) of the Exchange Act Requires a Showing of Mere Negligence, Not Scienter May 8, 2018 In Varjabedian v. Emulex, the Ninth Circuit recently held that plaintiffs bringing
More informationUNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE. Case No.:
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE CYNTHIA PITTMAN, Individually and On Behalf of All Others Similarly Situated, Case No.: v. Plaintiff, CLASS ACTION COMPLAINT FOR VIOLATIONS OF
More informationCase 3:11-cv JBA Document 200 Filed 05/13/11 Page 1 of 6 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
Case 3:11-cv-00078-JBA Document 200 Filed 05/13/11 Page 1 of 6 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SECURITIES AND EXCHANGE COMMISSION, Plaintiff, Civil Action No. 11-cv-78 (JBA v. FRANCISCO
More informationRULE 10b-5 AS APPLICABLE TO NEGOTIATED M+A TRANSACTIONS
RULE 10b-5 AS APPLICABLE TO NEGOTIATED M+A TRANSACTIONS This informal memo collects some relevant sources on the application of Rule 10b-5 to M+A transactions. 1. Common law fraud differs from state to
More informationTAKING SECTION 10(B) SERIOUSLY: CRIMINAL ENFORCEMENT OF SEC RULES
TAKING SECTION 10(B) SERIOUSLY: CRIMINAL ENFORCEMENT OF SEC RULES Steve Thel * This Article examines the role of section 10(b) of the Securities Exchange Act and Rule 10b-5 in public and private enforcement
More informationCase 3:17-cv VAB Document 11 Filed 04/18/17 Page 1 of 5 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
Case 3:17-cv-00155-VAB Document 11 Filed 04/18/17 Page 1 of 5 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SECURITIES AND EXCHANGE COMMISSION, Plaintiff, v. Civil Action No. 3:17-cv-00155-VAB MARK
More information11? "76WiA, y01\v7-aikt ' DAVID DE
Case :-cv-09-psg -SS Document 1 Filed 0/01/ Page 1 of Page ID #: ' l i ^^^' a-^ r]^ m Ln r-- ^ ^ UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CAFORNIA L ` ' Ca Y AND ON BEHALF OF ALL OTHERS SIMILARLY
More informationUNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT. August Term (Argued: March 10, 2016 Decided: May 4, 2016) Docket No.
15 536 United States v. Tagliaferri UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT August Term 2015 (Argued: March 10, 2016 Decided: May 4, 2016) Docket No. 15 536 UNITED STATES, Appellee, v. JAMES
More informationFollow this and additional works at:
2005 Decisions Opinions of the United States Court of Appeals for the Third Circuit 11-9-2005 In Re: Tyson Foods Precedential or Non-Precedential: Non-Precedential Docket No. 04-3305 Follow this and additional
More informationALI-ABA Course of Study Regulation D Offerings and Private Placements
381 ALI-ABA Course of Study Regulation D Offerings and Private Placements Cosponsored by the Securities Law Section of the Federal Bar Association March 15-17, 2012 Scottsdale, Arizona Due Diligence in
More informationUNITED STATES DISTRICT COURT DISTRICT OF NEVADA. Case No. Jury Trial Demanded
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA PLAINTIFF, individually and on behalf of all others similarly situated, v. Plaintiff, Spectrum Pharmaceuticals, Inc., and Rajesh Shrotriya, Defendants. Case
More informationLorenzo v. SEC Supreme Court Issues Decision on Scheme Liability Under Rule 10b-5
Lorenzo v. SEC Supreme Court Issues Decision on Scheme Liability Under Rule 10b-5 U.S. Supreme Court Rules That Defendants Can Be Held Primarily Liable for Securities Scheme Fraud for Knowingly Disseminating
More informationCase 1:14-cv CRC Document 222 Filed 10/03/18 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA.
Case 1:14-cv-01002-CRC Document 222 Filed 10/03/18 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA SECURITIES AND EXCHANGE COMMISSION, Plaintiff, Case No. 1:14-cv-01002 (CRC)
More informationGAZETTE OF INDIA EXTRA-ORDINARY. PART (II) OF SECTION 3, SUB-SECTION (ii) PUBLISHED BY AUTHORITY SECURITIES AND EXCHANGE BOARD OF INDIA NOTIFICATION
GAZETTE OF INDIA EXTRA-ORDINARY PART (II) OF SECTION 3, SUB-SECTION (ii) PUBLISHED BY AUTHORITY SECURITIES AND EXCHANGE BOARD OF INDIA NOTIFICATION Mumbai, the 17th July, 2003 SECURITIES AND EXCHANGE BOARD
More informationFinancial Services. New York State s Martin Act: A Primer
xc Financial Services JANUARY 15, 2004 / NUMBER 4 New York State s Martin Act: A Primer New York State s venerable Martin Act gives New York law enforcers an edge over the Securities and Exchange Commission.
More informationCase 1:19-cv DLC Document 1 Filed 01/03/19 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Case 1:19-cv-00070-DLC Document 1 Filed 01/03/19 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CHARLES MASIH, INDIVIDUALLY and ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, v. Plaintiff,
More informationCRIMINAL LIABILITY FOR FALSE STATEMENTS: 1001 THINGS TO WORRY ABOUT DURING FERC AND CFTC INVESTIGATIONS OF ENERGY COMPANIES AND INDIVIDUALS
CRIMINAL LIABILITY FOR FALSE STATEMENTS: 1001 THINGS TO WORRY ABOUT DURING FERC AND CFTC INVESTIGATIONS OF ENERGY COMPANIES AND INDIVIDUALS Stephen P. Freccero Synopsis: In recent years, the FERC and CFTC
More informationThe Spoofing Statute Is Here To Stay
Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com The Spoofing Statute Is Here To Stay By Clifford
More information15 USC 80b-3. NB: This unofficial compilation of the U.S. Code is current as of Jan. 4, 2012 (see
TITLE 15 - COMMERCE AND TRADE CHAPTER 2D - INVESTMENT COMPANIES AND ADVISERS SUBCHAPTER II - INVESTMENT ADVISERS 80b 3. Registration of investment advisers (a) Necessity of registration Except as provided
More informationCase 1:17-cv KPF Document 1 Filed 11/27/17 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) ) ) ) ) ) ) ) ) ) ) ) ) )
Case 1:17-cv-09261-KPF Document 1 Filed 11/27/17 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK XIYA QIAN, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff,
More informationCase 1:18-cv ER Document 1 Filed 01/18/18 Page 1 of 25
Case 1:18-cv-00466-ER Document 1 Filed 01/18/18 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CHARLES FERRARE, Individually and on Behalf of All Others Similarly Situated, v.
More informationU.C.A Title. This chapter is known as the Utah False Claims Act.
U.C.A. 1953 26-20-1 26-20-1. Title This chapter is known as the Utah False Claims Act. U.C.A. 1953 26-20-2 26-20-2. Definitions As used in this chapter: (1) Benefit means the receipt of money, goods, or
More informationCase 2:17-cv CCC-JBC Document 1 Filed 11/29/17 Page 1 of 15 PageID: 1 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY
Case 2:17-cv-12188-CCC-JBC Document 1 Filed 11/29/17 Page 1 of 15 PageID: 1 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY Individually and on behalf of all others similarly situated, Plaintiff, v.
More informationThe SEC proposes to codify the rule as a new Part 205 to Chapter 17 of the Code of Federal Regulations.
SEC PROPOSES RULES OF PROFESSIONAL CONDUCT FOR ATTORNEYS APPEARING AND PRACTICING BEFORE THE SEC SIMPSON THACHER & BARTLETT LLP DECEMBER 16, 2002 On November 21, 2002, the Securities and Exchange Commission
More informationISDA AUGUST 2012 DF SUPPLEMENT 1
ISDA AUGUST 2012 DF SUPPLEMENT 1 published on August 13, 2012, by the International Swaps and Derivatives Association, Inc. 1 This DF Supplement is intended to address requirements of the following final
More informationELDERSERVE HEALTH, INC. FALSE CLAIMS ACTS SUMMARY
FEDERAL FALSE CLAIMS ACT as amended, 31 U.S.C. 3729-3733 (FCA) FRAUD ENFORCEMENT AND RECOVERY ACT OF 2009 (FERA) PATIENT PROTECTION and AFFORDABLE CARE ACT of 2010 (PPACA) FCA Imposes liability on persons
More informationregulatory filings made by GALENA BIOPHARMA, INC. ( Galena or the Company ), with
JUSTINE FISCHER, ATTORNEY AT LAW Justine Fischer, OSB #81224 710 S.W. Madison Street, Ste 400 Portland, OR 97205 Telephone: (503) 222-4326 Facsimile: (503) 222-6567 Jfattyor@aol.com GLANCY BINKOW & GOLDBERG
More informationSUPREME COURT OF THE UNITED STATES
Cite as: 532 U. S. (2001) 1 NOTICE: This opinion is subject to formal revision before publication in the preliminary print of the United States Reports. Readers are requested to notify the Reporter of
More informationChief Compliance Officer Annual Report Requirements for Futures Commission. Merchants, Swap Dealers, and Major Swap Participants; Amendments to Filing
This document is scheduled to be published in the Federal Register on 11/16/2016 and available online at https://federalregister.gov/d/2016-27525, and on FDsys.gov 6351-01-P COMMODITY FUTURES TRADING COMMISSION
More informationCriminal Liability Hong Kong s Auditors in the Firing Line
Accountants August 2012 Update Criminal Liability Hong Kong s Auditors in the Firing Line On 12 July 2012, the Companies Bill was passed by the Legislative Council marking a significant milestone in the
More informationIN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION
Case 113-cv-01104-TWT Document 40 Filed 03/16/16 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION SECURITIES AND EXCHANGE COMMISSION, Plaintiff vs.
More informationIN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS GALVESTON DIVISION
Case 3:10-cv-00252 Document 1 Filed in TXSD on 06/29/10 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS GALVESTON DIVISION HUNG MICHAEL NGUYEN NO. an individual; On
More information--X. CASE No.: --X. Plaintiff John Gauquie ( Plaintiff ), individually and on behalf of all other persons
Case 1:14-cv-06637-FB-SMG Document 1 Filed 11/12/14 Page 1 of 16 PageID #: 1 THE ROSEN LAW FIRM, P.A. Laurence M. Rosen, Esq. (LR 5733) Phillip Kim, Esq. (PK 9384) Kevin Chan, Esq. (KC 0228) 275 Madison
More informationAgreement between the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB) regarding FOIA consultations, 2012
Description of document: Requested date: Released date: Posted date: Title of document Source of document: Agreement between the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau
More informationDefendants. Plaintiff, Jonas Grumby, individually and on behalf of all other persons and entities
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW SEARCHLAND JONAS GRUMBY, On Behalf of Himself and All Others Similarly Situated, v. Plaintiff, VOLTERON CORP. and JANE DOE and JOHN DOE, in their individual
More informationTEMPLATE: DO NOT SEND TO NFA NATIONAL FUTURES ASSOCIATION
Instructions for Using the Exempt Foreign Firm Application Template This document is not an application form. Do not send this document to NFA. It is a template that you may use to assist in filing the
More informationBusiness Crimes Perspectives
Business Crimes Perspectives In This Issue: March 2010 Sitting en banc, the First Circuit vacated a key portion of its prior panel decision and affirmed the district court s dismissal of the SEC s Section
More informationPOLICIES AND PROCEDURES FOR DETECTING AND PREVENTING FRAUD, WASTE AND ABUSE
MAIMONIDES MEDICAL CENTER SUBJECT: FALSE CLAIMS AND PAYMENT FRAUD PREVENTION 1. PURPOSE Maimonides Medical Center is committed to fully complying with all laws and regulations that apply to health care
More informationUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION ) ) ) ) ) ) ) ) ) )
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION UNITED STATES OF AMERICA, v. JEFFREY K. SKILLING, and KENNETH L. LAY, Plaintiff, Defendants. Crim. No. H-04-25 (Lake, J. DEFENDANT
More information- 1 - Class Action Complaint for Violation of the Federal Securities Laws
Case :-cv-0 Document Filed /0/ Page of Page ID #: 0 Laurence M. Rosen, Esq. (SBN ) THE ROSEN LAW FIRM, P.A. South Grand Avenue, Suite 0 Los Angeles, CA 00 Telephone: () -0 Facsimile: () - Email: lrosen@rosenlegal.com
More informationAgent/Agency Agreement
Agent/Agency Agreement This Agent/Agency Agreement ( Agreement ) between CareConnect Insurance Company Inc. and ( CCIC ) and ( Agent ) sets forth the terms and conditions under which Agent may sell health
More informationCase 2:16-cv RFB-GWF Document 4 Filed 09/29/16 Page 1 of 12
Case :-cv-0-rfb-gwf Document Filed 0// Page of 0 BLOCK & LEVITON LLP Jeffrey C. Block, Esq. (pro hac vice application to be filed) Joel A. Fleming, Esq. (pro hac vice application to be filed) Federal Street,
More informationUNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
, Individually and On Behalf of All Others Similarly Situated, UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case No.: 1 1 0 1 v. Plaintiff, BRISTOL-MYERS SQUIBB COMPANY, MICHAEL GIORDANO,
More informationNORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Securities And Exchange Commission v. JSW Financial Inc. et al Doc. 5 1 2 3 4 5 7 JINA L. CHOI (N.Y. Bar No. 997) ROBERT L. TASHJIAN (Cal. Bar No. 1007) tashjianr a~see.~ov. STEVEN D. BUCHHOLZ (Cal. Bar
More informationCase 1:18-cv CM Document 6 Filed 12/21/18 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Case 1:18-cv-12089-CM Document 6 Filed 12/21/18 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THOMAS F. COOK, INDIVIDUALLY and ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, v. Plaintiff,
More informationCase 1:15-cv BAH Document 1 Filed 03/03/15 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Case 1:15-cv-00307-BAH Document 1 Filed 03/03/15 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA : UNITED STATES SECURITES AND : EXCHANGE COMMISSION, : : Case No. : Plaintiff,
More informationOPINION AND ORDER. Securities Class Action Complaint ("Complaint") pursuant to Rules 9(b) and 12(b)(6) of the
ORIGI NAL ' Case 1:05-cv-05323-LTS Document 62 Filed 07/14/2006 Page 1 of 14 USDC SDNY DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: x DATE FILED: D 7/,V/
More informationUNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA. No. Plaintiff, : :
Case 2:15-cv-03979-R-PJW Document 1 Filed 05/27/15 Page 1 of Page ID #:1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 21 Jennifer Pafiti (SBN 282790) POMERANTZ LLP 468 North Camden Drive Beverly Hills,
More informationIN THE UNITED STATES COURT FOR THE DISTRICT OF UTAH CENTRAL DIVISION
Case 2:12-cv-00852-EJF Document 2 Filed 09/06/12 Page 1 of 21 & & IN THE UNITED STATES COURT FOR THE DISTRICT OF UTAH CENTRAL DIVISION Behalf of All Others Similarly Situated, Plaintiff, CLASS ACTION COMPLAINT
More informationUNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA Case No:
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA Case No: PLAINTIFF, Individually and on behalf of all others similarly situated, Plaintiff, v. ENDOLOGIX, INC., JOHN MCDERMOTT, and VASEEM MAHBOOB,
More informationBeyond Shall : Dodd-Frank s Permissive Rulemakings
Gabriel D. Rosenberg and Jeremy R. Girton 1 Davis Polk & Wardwell LLP The burden on regulatory agencies to complete the hundreds of rulemakings required by the Dodd-Frank Act has garnered a great deal
More informationUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA. Plaintiff,
Case :-cv-0-gpc-blm Document Filed 0/0/ PageID.0 Page of 0 0 SECURITIES AND EXCHANGE COMMISSION, v. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Plaintiff, BLOCKVEST, LLC and REGINALD BUDDY
More informationPOLICY STATEMENT. Topic: False Claims Act Date Effective: 10/13/08. X Revised New Section: Corporate Compliance Number: 10.05
The Arc of Ulster-Greene 471 Albany Avenue Kingston, NY 12401 845-331-4300 Fax: 331-4931 www.thearcug.org POLICY STATEMENT Topic: False Claims Act Date Effective: 10/13/08 X Revised New Section: Corporate
More informationDIRECTIVE 2014/57/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 2014 on criminal sanctions for market abuse (market abuse directive)
12.6.2014 Official Journal of the European Union L 173/179 DIRECTIVE 2014/57/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 2014 on criminal sanctions for market abuse (market abuse directive)
More informationCase 2:15-cv GMN-PAL Document 62 Filed 06/16/16 Page 1 of 6
Securities and Exchange Commission v. Ascenergy LLC et al Doc. Case :-cv-0-gmn-pal Document Filed 0// Page of DAVID REECE (TX Bar No. 000) Email: ReeceD@sec.gov KEEFE BERNSTEIN (TX Bar No. 00) Email: BernsteinK@sec.gov
More informationCase 1:03-cv LJM-TAB Document 745 Filed 05/22/07 Page 1 of 8 PageID #: 8174
Case 1:03-cv-01659-LJM-TAB Document 745 Filed 05/22/07 Page 1 of 8 PageID #: 8174 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION SECURITIES AND EXCHANGE COMMISSION, ) )
More informationCase 1:18-cv Document 1 Filed 09/14/18 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. Case No.:
Case 1:18-cv-08406 Document 1 Filed 09/14/18 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK IDA LOBELLO, Individually and on Behalf of All Others Similarly Situated, Case No.:
More informationUNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION IN THE MATTER OF ) ) DOCKET NO. RM83-31 EMERGENCY NATURAL GAS SALE, ) TRANSPORTATION AND EXCHANGE ) DOCKET NO. RM09- TRANSACTIONS
More informationUnited States Court of Appeals For the Eighth Circuit
United States Court of Appeals For the Eighth Circuit No. 16-3808 Nicholas Lewis, on Behalf of Himself and All Others Similarly Situated lllllllllllllllllllll Plaintiff - Appellant v. Scottrade, Inc. lllllllllllllllllllll
More informationH.R./S. In the A BILL. To protect the privacy of personal information of consumers, the promotion
1 11 TH CONGRESS SESSION H.R./S To ensure the privacy of personal information, the protection of consumers, and the promotion of innovation. In the A BILL To protect the privacy of personal information
More information