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Dorsey & Whitney LLP

The SEC Issues Marketing Rule FAQ on Calculating Gross and Net Performance

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The staff (“Staff”) of the SEC’s Division of Investment Management recently issued a new FAQ (the “FAQ”) on Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940 in which the Staff confirmed that the...more

Harris Beach Murtha PLLC

OIG’s Favorable Opinion: Employed Physicians Paid Bonuses Based on ASCs’ Net Profits

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This opinion addresses a proposed arrangement (“Proposed Arrangement”) between a multi-specialty physician practice (“Requestor”) that employs approximately 11 physician employees (“Physician Employees”). In addition to base...more

Farrell Fritz, P.C.

Summary Judgment in Lieu of Complaint Meets Business Divorce

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For most business divorce litigants, a dispositive win on the merits, even in a summary proceeding, can take years. Appraisal proceedings following a cash-out merger, for example, may involve multiple years of difficult...more

Foley & Lardner LLP

Dealer Net Profits Rise During Supply-Chain Crunch

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As everyone reading this blog well knows, there has been a shortage of new vehicles this year due to a variety of factors. Although the auto industry is continuing to struggle with supply-chain constraints, one area that is...more

Holland & Knight LLP

Fifth Circuit: SEC's Plan for Distributing Disgorged Amounts to Investors Satisfies Liu

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The U.S. Court of Appeals for the Fifth Circuit on Oct. 12, 2021, became the first federal appellate court to decide whether a disgorgement award entered against defendants in an U.S. Securities and Exchange Commission (SEC)...more

Amundsen Davis LLC

What Damages Can You Recover In A Non-Compete Case?

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In the typical non-compete lawsuit, an employer seeks to block the defendant, often an ex-sales representative, from calling on or doing business with the company’s clients. However, in some cases, the defendant succeeds in...more

McCarter & English, LLP

New PPP Rules Benefit Self-Employed Individuals

Last year, self-employed individuals who conducted their business without any employees could qualify for a Paycheck Protection Program (PPP) loan in an amount equal to approximately 20.8% (2.5 months divided by 12 months) of...more

Kilpatrick

KT Sound Bytes Episode 1 | The Effects of the Supreme Court Decision in Liu v. SEC

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We're pleased to announce the launch of our podcast, KT Sound Bytes! Our first episode features Partner Adria Perez and Associate Jessica Nwokocha, with assistance from Summer Associate Davis Brooke Caswell, discussing the...more

Faegre Drinker Biddle & Reath LLP

Liu v. SEC Decision Leaves Ambiguity on Disgorgement Limitations – How to Measure 'Business Expenses' Deductible From 'Illegal...

While the U.S. Supreme Court’s decision in Liu v. SEC limited the SEC’s disgorgement power, it also left open certain complicated issues that are now subject to interpretation. As we previously summarized, in an 8–1 vote, the...more

Sheppard Mullin Richter & Hampton LLP

Ninth Circuit Reverses SEC Disgorgement Award and Remands in First Decision Post-Liu

For the first time outside of the originating case itself, a federal appeals court was called upon to apply the principles governing disgorgement in SEC enforcement actions established by the United States Supreme Court’s...more

Cadwalader, Wickersham & Taft LLP

A Liu Look at Disgorgement: Ninth Circuit Vacates SEC Disgorgement Award

The U.S. Supreme Court’s landmark decision in Liu v. SEC is less than two months old, yet the ramifications of the decision on the SEC’s enforcement powers are already taking shape....more

Faegre Drinker Biddle & Reath LLP

Strange Bedfellows – How a Recent Security Fraud Opinion May Impact Consumer Fraud Class Actions

The U.S. Supreme Court’s recent decision in Liu v. SEC, No. 18-1501 (June 22, 2020), limiting the SEC’s ability to obtain monetary equitable relief in securities fraud litigation, may seem an odd topic for this blog. But Liu...more

Pillsbury - Policyholder Pulse blog

Disgorgement/Restitution Defense Continues to Lose Steam in Wake of Supreme Court Decision in Liu v. SEC

Late in June, the U.S. Supreme Court issued a decision in Liu v. SEC, a closely watched case in which the Court in an 8-1 opinion curtailed the authority of the Securities and Exchange Commission (SEC) to seek disgorgement of...more

Seyfarth Shaw LLP

Limits To ERISA’s Equitable Remedies — What The Supreme Court’s Latest Securities Act Decision Tells Us

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Seyfarth Synopsis: A recent Supreme Court decision on federal securities law may hold ramifications for ERISA practitioners by addressing whether disgorgement is an equitable remedy....more

Sheppard Mullin Richter & Hampton LLP

Maybe the FTC Can’t Take That to the Bank: The Supreme Court’s Decision in Liu v. SEC and Its Implications for the FTC’s Ability...

On July 9, 2020, the U.S. Supreme Court granted petitions for certiorari in FTC v. Credit Bureau Center and AMG Capital Management, LLC v. FTC, cases that question the Federal Trade Commission’s authority to demand equitable...more

Wilson Sonsini Goodrich & Rosati

Liu v. SEC: Foreshadowing a Challenge to the FTC’s Disgorgement Authority

In Liu v. Securities & Exchange Commission, the Supreme Court upheld, but circumscribed, the Securities and Exchange Commission's (SEC's) disgorgement authority by holding 8-1 that the SEC may seek disgorgement through its...more

Foley Hoag LLP - White Collar Law &...

Are Disgorgement Payments to the SEC Tax-Deductible? U.S. Supreme Court’s Decision in Liu v. SEC Complicates the Analysis

The U.S. Supreme Court’s decision last month in Liu v. SEC raises the question of whether disgorgement payments in SEC enforcement actions should now be deductible for federal income tax purposes. The Court held that a...more

King & Spalding

What is New After Liu: Unsettled Questions Surrounding SEC Disgorgement

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On June 22, 2020, in Liu v. SEC, the Supreme Court held in an 8-1 decision that the SEC is authorized under 15 U.S.C. § 78u(d)(5) (2015) to seek disgorgement as “equitable relief” in district court actions, as long as the...more

Pillsbury Winthrop Shaw Pittman LLP

The Supreme Court’s Decision in Liu and Insider Trading Enforcement

Although the Supreme Court handed the SEC a win by preserving its authority to seek disgorgement, the Liu decision limits that authority and creates uncertainty that will likely benefit defendants, particularly in insider...more

McCarter & English, LLP

Liu v. SEC—Supreme Court Limits SEC’s Ability To Seek Disgorgement

In Liu v. Securities & Exchange Comm’n, No. 18-1501, 2020 WL 3405845 (U.S. Jun. 22, 2020), the United States Supreme Court upheld the ability of the Securities and Exchange Commission (“SEC”) to seek disgorgement as an...more

Kilpatrick

Liu v. SEC: The U.S. Supreme Court Upholds SEC’s Power to Disgorge Profits Obtained Through Fraud, with Limits

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On June 22, 2020, in a Securities and Exchange Commission (SEC) enforcement action, the U.S. Supreme Court ruled that the SEC may disgorge profits obtained by companies through fraudulent practice, provided that such award...more

The Volkov Law Group

Supreme Court Restricts Disgorgement Remedy

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In an important case decided in June 2020, the Supreme Court, in Liu et al v. SEC, addressed the SEC’s ability to seek “equitable relief” in civil proceedings. In 2017, the Supreme Court, in Kokesh v. SEC, ruled that a...more

Mintz - Securities Litigation Viewpoints

Liu v. SEC —SCOTUS Weighs In, But Disgorgement Questions Remain

On June 22, 2020, the Court issued its 8-1 opinion in Liu et al. v. Securities and Exchange Commission, No. 18-1501, 591 U.S. ____, 2020 U.S. LEXIS 3374 (2020) (Sotomayor, J.), holding that a disgorgement award is “equitable...more

BakerHostetler

SEC Wins Fight to Retain Disgorgement Power But There's a Catch

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On June 22, 2020, the U.S. Supreme Court issued its highly anticipated decision in Liu v. Securities and Exchange Commission, which found that disgorgement awards that do not exceed a wrongdoer’s net profits (gross profits...more

Foley Hoag LLP - White Collar Law &...

Liu v. SEC: Supreme Court Upholds the SEC’s Disgorgement Power But the Quagmire Continues

Last week, the Supreme Court decided in Liu v. SEC that the SEC may continue to seek disgorgement in judicial proceedings as a form of equitable relief under the Securities Exchange Act. A ruling to the contrary would have...more

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