A recent defendant-friendly decision issued by the 2nd U.S. Circuit Court of Appeals helped keep the door slammed firmly shut against plaintiffs seeking to bring Rule 10b-5 securities fraud claims against “secondary actors.”

This is good news for defendants and persons such as law firms, investment banks and other professionals who have not made any allegedly false or misleading public statements themselves, but rather were merely involved in preparing public financial disclosure and offering documents that allegedly contain such statements.

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