Interpreting Reliance Two Years After Stoneridge
By William F. Sullivan, Douglas Koff, and Laura Karvosky
A little over two years ago, the U.S. Supreme Court decided Stoneridge Investment Partners, LLC v. Scientific-Atlanta Inc., 552 U.S. 148 (2008). Since then, Stoneridge, building upon Central Bank, has established the standard for addressing liability for defendants who did not issue the public statements at issue in civil cases brought by private parties under §10(b) of the Securities Act of 1934 (Exchange Act) and SEC Rule 10b-5. In analyzing such liability, courts have focused on whether plaintiffs could have relied on the actions of the non-issuer defendant.
Writing in the New York Law Journal, the authors examine a few of the key cases following Stoneridge.
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