2nd Circ. Has Made Morrison Standard Even More Arbitrary

Law360, New York (August 28, 2014, 9:49 AM EDT) -- The U.S Supreme Court in Morrison v. National Australia Bank held that Section 10(b) of the Exchange Act (and Rule 10b-5) could not be applied in an extraterritorial fashion. In doing so, the court overturned the longstanding "effects" test developed by the Second Circuit....

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