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In Morrison v. National Australia Bank Ltd., the Supreme Court held that Section 10(b)’s fraud prohibition only applies to “transactions in securities listed on domestic exchanges and domestic transactions in other securities.” In the 22 months since the high court decided Morrison, its jurisdictional bar has been broadly extended beyond the case’s narrow, “f-cubed” factual context: foreign plaintiffs suing foreign defendants in connection with securities traded on foreign exchanges. Morrison’s progeny have confirmed that suits against foreign companies involving transactions in securities listed on domestic exchanges will largely be nonstarters.

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