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Nevada Supreme Court: Judge, Not Jury, Decides Unambiguous Contract

In 2011, a local water district in Nevada entered into a lease agreement with Paradise Canyon, LLC to provide shares of water for irrigating the Wolf Creek Golf Club.   The lease agreement granted Paradise Canyon a right of...more

If You Agree That Stock Issuance Was Not "Compensation, Salary, Or Income", You May Want To Think Carefully Before Issuing A Form...

Ten years ago, Hovik Nazaryan sued Femtometrix, Inc. claiming that the company had issued shares to him than it had promised.  The parties settled the lawsuit.  The settlement agreement provided that the stock issued to Mr....more

Ninth Circuit Upholds DFPI's Commercial Financing Disclosure Rules

On September 30, 2018, California enacted SB 1235, codified at California Financial Codes sections 22800–22805. SB 1235 requires that an offer of commercial financing for $500,000 or less be accompanied by disclosures of: (1)...more

If The Shares Of A Chinese Company Are Delisted, What Happens To Trading In California?

Yesterday's Wall Street Journal includes a story about the possible delisting of shares of Chinese companies.  Shares of companies that are listed, or authorized for listing, on a national securities exchange (or tier or...more

Digital Financial Assets - Out Of The Frying Pan And Into The Fire?

The application of the securities laws to digital financial assets has been fraught for lawyers and their clients. After taking a hard line that many of these assets were securities under the federal securities laws, the...more

Nevada Supreme Court: Chapter 7 Filing Defeats Shareholder Breach Of Fiduciary Claim

Globe Photos, Inc. owned a portfolio of millions of images of celebrities and musicians, including Marilyn Monroe, the Beatles, and Jimi Hendrix, some taken by famous photographers such as Frank Worth.  Despite these assets,...more

Fidelity National Financial, Inc. Takes Another Run On Nevada Move

Last year, I reported that the stockholders of Fidelity National Financial, Inc. had failed to approve a proposal to convert the corporation from a Delaware to a Nevada corporation.  The company has not given up on the...more

The Possible Securities Act Implications Of Harvard's "Nyet" To Government Civil Rights Reform Demands

Last week, the United States General Services Administration, Department of Education, and Department of Health and Human Services sent a letter to Alan M. Garber, the President of Harvard University, and Penny Pritzker, Lead...more

When Do Blue Sky Laws Apply?

In my experience, many securities lawyers are well versed in the federal securities laws, but have little experience with state securities laws.  This is understandable because federal law in many cases preempts state...more

Are Many Nasdaq Global Select Corporations Subject To The California General Corporation Law?

Only a few publicly traded corporations are incorporated in California.  Most either started life in Delaware or later decamped to that state (and more recently other states).  Nonetheless, many of these corporations have...more

For Delaware, The Garden Party May Soon Be Ending Despite SB21

In speaking with a reporter earlier this year, I observed that this proxy season will tell whether DExit has legs.  While not exactly, a flood, several well-known and lesser-known corporations have recently filed proxy...more

Delaware LLCs - "I See Trouble On the Way"

Delaware had barely birthed changes to Section 144 of its General Corporation Law when the Plumbers & Fitters Local 295 Pension Fund filed a complaint challenging those changes.  The plaintiff seeks a declaration that the...more

Unreasonableness Or Carelessness Is Insufficient To Prove Liability In Nevada

Nevada's exculpatory statute, NRS 78.138(7), requires a plaintiff to both rebut a statutory presumption of good faith and prove a breach of fiduciary duty involving intentional misconduct, fraud, or a knowing violation of the...more

Intentionally Discriminatory Public Offering Stalled At The SEC

In this February post, I pondered the question of whether an issuer could allocate shares on the basis of race, gender or ethnicity.  That post was inspired by the case of  Glennon v. Johnson, U.S. Dist. Ct. Case No....more

Another Post SB21 Proposal To Reincorporate From Delaware To Nevada

The ink has barely dried on Delaware's hotly debated amendments to its General Corporation Law and already another company has proposed reincorporation in Nevada.  In preliminary proxy materials filed yesterday with the...more

Tempus Fugit Ad Nevada

Three days after Delaware’s governor, Matt Meyer, signed into law controversial amendments to Delaware's General Corporation Law, another publicly traded company filed preliminary proxy materials with the Securities and...more

Can Investors Themselves Be Liable For A Failure To Register The Offer And Sale Of Securities?

Section 12(a)(1) of the Securities Act of 1933 imposes liability on sellers of securities who violate that Act's registration and prospectus delivery requirements.  Because the statute refers to sellers, it seems unlikely...more

Can An Employer Require Employees To Invest In The Business?

Employee stock bonus, stock purchase, and stock option plans are extremely common.  Most employees and prospective employees are undoubtedly happy to receive these types of equity compensation awards, but can an employer...more

FinCEN Exempts U.S. Companies and U.S. Persons from Beneficial Ownership Reporting Requirements

An interim final rule issued by the Financial Crimes Enforcement Network (FinCEN), makes the following significant changes to beneficial ownership information reporting (BOIR) requirements: defines a “reporting company”...more

Can Common Interest Communities Ban Religious Displays On Doors And Doorframes?

The Nevada legislature is currently considering a bill, SB 201, that would restrict, with certain exceptions, an association or unit’s owner who rents or leases his or her unit from prohibiting a unit’s owner or occupant of a...more

SEC Abandons Defense Of Brobdingnagian Climate Change Disclosure Rule

Three years ago, the Securities and Exchange Commission issued a nearly 500 page rule proposal that would require registrants to provide certain climate-related information in their registration statements and annual...more

Is Registration As A Foreign Corporation A Form Of Compelled Consent?

Not too long ago, I wrote about a bill that is currently pending in the Nevada legislature, AB 158.  This bill would authorize Nevada courts to exercise general personal jurisdiction over entities on the sole basis that the...more

FinCen Issues A Huge Reprieve Form Domestic Reporting Companies

O frabjous day!  the Financial Crimes Enforcement Network (FinCEN) late last Friday issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information...more

What Vice Chancellor Strine Got Wrong In Massey Energy Co.

Vice Chancellor Leo Strine famously wrote that "Delaware law does not charter law breakers".  In re Massey Energy Co., 2011 WL 2176479, at *20 (Del. Ch. May 31, 2011).  Professor William J. Moon picks up on this theme in a...more

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