The narrow focus of Janus Capital Group, Inc. v. First derivative Traders, 131 S.Ct. 2296 (2011) may have a significant impact in private damage actions and SEC enforcement cases. Focusing on the word “make” in the second clause of Rule …
The narrow focus of Janus Capital Group, Inc. v. First derivative Traders, 131 S.Ct. 2296 (2011) may have a significant impact in private damage actions and SEC enforcement cases. Focusing on the word “make” in the second clause of Rule …
The distinction between primary and secondary liability has been repeatedly litigated in securities damage cases, and to a lesser extent in SEC enforcement actions, since the Supreme Court handed down its decision in Central Bank of Denver v. First Interstate …