Jenner & Block

SEC Bulletin Vol. 2, Issue 2

This issue of Jenner & Block's SEC Bulletin discusses:

  • "Gun-jumping," i.e. communications surrounding a securities offering in violation of securities law.
  • A dismissal by a U.S. Court of Appeals of an SEC cease-and-desist order concerning Rule 14d-10(a)(1) - the "All Holders Rule."
  • Anticipated forthcoming guidance for evaluating the materiality of accounting errors.
  • A reversal on appeal of a decision regarding the use of proxy cards in shareholder letter campaigns.