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In our April column, we discussed recent limits on the scope of diversity jurisdiction set by the U.S. District Court for the Southern District of New York. Since then, the U.S. Court of Appeals for the Second Circuit, followed closely by Southern District Judge Jed S. Rakoff, have announced limits on a more obscure form of subject matter jurisdiction arising under the Edge Act, 12 U.S.C. Section 632, which provides for original and removal jurisdiction in cases involving international banking transactions by federally chartered banks or their extraterritorial subsidiaries. In Dexia v. Bear Stearns,1 Rakoff, sua sponte, reversed his own earlier decision upholding Edge Act jurisdiction, after the Second Circuit called for a narrow reading of that statute's jurisdictional grant in its own recent decision in American International Group v. Bank of America.2

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