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On April 19, 2011, Judge Laura Taylor Swain of the U.S. District Court for the Southern District of New York dismissed a $2.4 million suit against the U.S. government alleging gross negligence on the part of the Securities and Exchange Commission (SEC) in the agency’s failure to uncover Bernard Madoff’s massive Ponzi scheme. In Molchatsky v. U.S., 09-cv-08697 (S.D.N.Y. April 19, 2011), Judge Swain granted the federal government’s motion to dismiss for lack of subject matter jurisdiction.