News & Analysis as of

Intent to Defraud Supreme Court of the United States

Bradley Arant Boult Cummings LLP

Ciminelli One Year Later: The Evolving Reach of the Wire Fraud Statute

The federal wire fraud statute, 18 U.S.C. § 1343, is one of the commonly used statutes in federal white-collar criminal cases. In our digital age, nearly any significant fraud or scheme could probably be charged as a wire...more

Warner Norcross + Judd

Supreme Court Resolves Circuit Split and Holds that Wire Fraud Requires Deprivation of Traditional Property Interest

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In Ciminelli v. United States, the United States Supreme Court resolved a decades-long circuit split and clarified that to be guilty of federal wire fraud, prosecutors must prove that the defendant’s scheme to defraud...more

Haug Partners LLP

Supreme Court to Hear Case Regarding When Providing Inaccurate Copyright Registration Information Affects a Registration’s...

Haug Partners LLP on

The Supreme Court has granted a petition for writ of certiorari in Unicolors, Inc. v. H&M Hennes & Mauritz, L.P. to determine whether invalidation of copyright registrations under Section 411(b) of the Copyright Act has an...more

Dorsey & Whitney LLP

SCOTUS Agrees to Consider Whether Copyright Act Section 411 Requires an Intent to Defraud

Dorsey & Whitney LLP on

The U.S. Supreme Court recently granted certiorari to tackle a technical copyright registration question: when a defendant alleges knowing inaccuracies in a copyright registration, does 17 U.S.C. § 411 require referral to the...more

ArentFox Schiff

Supreme Court Case to Watch: When and How Copyright Registrations Can Be Invalidated for Inaccuracies

ArentFox Schiff on

Last week the Supreme Court agreed to hear the case Unicolors, Inc. v. H & M Hennes & Mauritz, LP, which considers when inaccuracies in a US copyright application can be used to invalidate a resulting registration. The case...more

Buchalter

The Supreme Court Agrees to Decide Whether Immaterial Registration Errors Can Serve as the Basis for Invalidating Copyright...

Buchalter on

On June 1, 2021, the U.S. Supreme Court granted certiorari in a case that will likely determine once and for all whether courts are empowered to void copyright registrations based on immaterial registration errors, or whether...more

Skadden, Arps, Slate, Meagher & Flom LLP

In Malouf, Tenth Circuit Applies Supreme Court’s Lorenzo Decision

On August 13, 2019, in the first case by a U.S. Court of Appeals to apply the U.S. Supreme Court’s recent decision in Lorenzo v. SEC, 139 S. Ct. 1094 (2019), the U.S. Court of Appeals for the Tenth Circuit held that the...more

Jones Day

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

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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

Carlton Fields

Supreme Court Casts a Wide Net with Rule 10b-5

Carlton Fields on

The U.S. Supreme Court recently held that someone doesn’t need to have “made” a false or misleading statement to have primary liability under the securities fraud rules. ...more

McDermott Will & Emery

Observations from the Enforcement Directors at SEC’s Annual Conference

McDermott Will & Emery on

Enforcement Co-Directors Stephanie Avakian and Steven Peikin recently addressed notable enforcement decisions, actions and trends affecting public companies and regulated entities. On April 8 and 9, 2019, the US Securities...more

Hogan Lovells

Supreme Court expands liability for false statements under the federal securities laws

Hogan Lovells on

On March 27, the Supreme Court issued its much-anticipated decision addressing whether someone who is not the "maker" of a misstatement can nonetheless be primarily liable for fraud under the federal securities laws, when the...more

Robins Kaplan LLP

SCOTUS Opens Door to Potential Expansion of Rule 10b-5 Liability for Misstatements

Robins Kaplan LLP on

On March 27, 2019, Justice Breyer, writing for a six-Justice majority of the Supreme Court, issued a decision in Lorenzo v. SEC, 139 S. Ct. 1094 (2019), holding that one who knowingly distributes a material misstatement can...more

Foley & Lardner LLP

A Summary of Certain Recent Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Sender Primary Liability for Misstatements in PPMs and Prospectuses: Lorenzo v. SEC (No. 17-1077 -- U.S. – 2019). On March 27th, the Supreme Court issued a 1934 Act Rule 10b-5 opinion that will have implications for...more

King & Spalding

Supreme Court Affirms Lorenzo v. SEC, Expanding the Scope of Primary Liability for Securities Fraud

King & Spalding on

On March 27, 2019, the U.S. Supreme Court issued its decision in Lorenzo v. SEC,[i] affirming the expansive view of the U.S. Securities and Exchange Commission (“SEC” or “Commission”) that, under the right circumstances,...more

Husch Blackwell LLP

U.S. Supreme Court Expands Potential For Liability In Capital Market Transactions

Husch Blackwell LLP on

On March 27, 2019, the Supreme Court, in Francis V. Lorenzo v. Securities and Exchange Commission, held (in a 6-2 decision) that a person who (i) knowingly disseminates false and misleading statements to prospective investors...more

K&L Gates LLP

Supreme Court Wades Into Circuit Split, Endorses Broader View of "Scheme Liability" for Disseminating False Statements

K&L Gates LLP on

On Wednesday, March 27, 2019, the U.S. Supreme Court ruled in favor of the Securities and Exchange Commission (“SEC”) and endorsed a broad view of so-called “scheme liability” under SEC Rule 10b-5(a) and (c)....more

Jones Day

Supreme Court Expands Securities-Fraud Scheme Liability

Jones Day on

The dissemination of false or misleading information can give rise to primary liability. In Lorenzo v. Securities and Exchange Commission, the Supreme Court held that someone who (with intent to defraud) disseminates a...more

White & Case LLP

Lorenzo v. SEC: Disseminating false information can create Rule 10b-5 liability even for those who did not "make" the false...

White & Case LLP on

On March 27, 2019, the Supreme Court issued its opinion in Lorenzo v. SEC, affirming the decision of the United States Court of Appeals for the District of Columbia. The Court held that "dissemination of false or misleading...more

Pillsbury Winthrop Shaw Pittman LLP

Supreme Court: Intentionally Disseminating a False Statement One Did Not “Make” May Still Violate SEC Rule 10b-5

In a significant ruling, the U.S. Supreme Court has expanded the potential liability of those involved in disseminating material misrepresentations to potential investors—exposing them to primary liability under SEC Rule...more

BakerHostetler

SCOTUS Skirts Janus on Securities Liability for Distributing False or Misleading Information

BakerHostetler on

The Supreme Court of the United States recently upheld a broad interpretation of the antifraud rule of the federal securities laws that likely will have far-reaching implications for enforcement and civil actions....more

Kramer Levin Naftalis & Frankel LLP

The Supreme Court Broadens Liability for False Statements Under Rule 10b-5 to “Disseminators”

In its 2011 Janus decision, the Supreme Court emphasized that SEC Rule 10b-5 imposes liability for a false statement in connection with a securities transaction only on the “maker” of the statement, the “person or entity with...more

Latham & Watkins LLP

Supreme Court Ruling Extends Reach of Primary Liability for Securities Fraud

Latham & Watkins LLP on

Highly anticipated opinion extends primary liability for securities fraud beyond the “maker” of false statements. Key Points: ..The Court held that a defendant’s act of sending emails drafted by another, that the...more

Locke Lord LLP

U.S. Supreme Court Expands Reach of 10b-5 Liability

Locke Lord LLP on

On March 27, 2019, the U.S. Supreme Court, in Lorenzo v. SEC, No. 17-1077 (2019), held that dissemination of false or misleading statements with intent to defraud violates Rules 10b–5(a) and (c) under the Securities Exchange...more

Sheppard Mullin Richter & Hampton LLP

United States Supreme Court Holds That Knowing Dissemination of False Statements Made by Others Can Constitute Primary “Scheme...

In Lorenzo v. Securities & Exchange Comm., No. 17-1077, 2019 WL 1369839 (U.S. Mar. 27, 2019), the Supreme Court of the United States (Breyer, J.) held that an individual who did not “make” a false or misleading statement...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Supreme Court: Disseminators of False Statements with Intent to Defraud can be Held Liable Under Securities Exchange Act Rule...

• The United States Supreme Court held that a disseminator of a false statement with intent to defraud can be held liable under subsections (a) and (c) of Rule 10b-5, §10(b) of the Exchange Act and §17(a)(1) of the Securities...more

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