“Big Boy” Letters Revisited

Law360 (December 20, 2007, 12:00 AM EST) -- “Big Boy” letters continue to evoke considerable debate. Within the past month, two senior officials with the staff of the U.S. Securities and Exchange Commission have said that, regardless of their effectiveness as a defense in private securities litigation, “Big Boy” letters are no defense to an SEC enforcement action.[1]

Securities traders sometimes use “Big Boy” letters to document a potential defense against later allegations of insider trading. See our Alert Memorandum, “Big Boy” Letters and the Enforcement Implications of SEC v. Barclays, No. 43-2007 (June...
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