Client Alerts

Public Company Update: D.C. District Court Rules Proxy Voting Advice Beyond The Scope Of Federal Proxy Rules

March 06, 2024

By Brad Bondi,Sean Donahue,Eduardo Gallardo,Ruonan Song,& Spencer Francis Young

On February 23, 2024, the U.S. District Court for the District of Columbia ruled in favor of Institutional Shareholder Services Inc. on the party’s motions for summary judgment, ending a years long dispute over whether proxy voting advice for a fee constitutes solicitation subject to the federal proxy rules. The court held that the SEC acted in excess of its statutory authority when it amended the proxy rules’ definition of “solicit” and “solicitation” in 2020 to include proxy voting advice for a fee.


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Practice Areas

Securities and Capital Markets


For More Information

Image: Brad Bondi
Brad Bondi

Partner, Litigation Department

Image: Sean Donahue
Sean Donahue

Partner, Corporate Department

Image: Eduardo Gallardo
Eduardo Gallardo

Partner, Corporate Department

Image: Ruonan Song
Ruonan Song

Associate, Corporate Department

Image: Spencer Francis Young
Spencer Francis Young

Senior Practice Group Attorney

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