Del. Ruling May Curb Cyan-Prompted Class Actions

Law360 (March 20, 2020, 5:53 PM EDT) -- Friday marked two years since the U.S. Supreme Court held in Cyan Inc. v. Beaver County Employees Retirement Fund that class actions brought under the Securities Act of 1933 may be filed in state court and are not removable to federal court.[1] In the wake of Cyan, the number of 1933 Act class actions filed in state court increased dramatically.

That in turn gave rise to a significant uptick in parallel state and federal proceedings — instances in which there are both a state court class action under the 1933 Act and a federal court class action based on similar allegations under...

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