Circuit court erred in determining the two-year limitations period of Securities Exchange Act § 16(b) is tolled until a § 16(a) statement is filed, since tolling ceases when fraudulently concealed facts are or should have been discovered by a plaintiff.
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U.S. SUPREME COURT
Credit Suisse Securities (USA) v. Simmonds
New Jersey Law Journal
March 28, 2012
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