Finance & Securities 
Direct Shareholder Claims Allowed in Apple Stock Backdating Scheme–but No Remedy
Shareholders argued their economic loss was a diluted stock price that could be remedied by recission of management’s vote for the backdated options.
The Ninth Circuit Court rejected this distinction, holding: “the PSLRA does not differentiate between plaintiffs seeking legal and equitable remedies, and thus, without an allegation of economic loss, no remedy, equitable or otherwise, is available.”
US Supreme Court Requires “Direct Causal Relationship” in Proving RICO Damages
If the RICO conduct caused a more direct injury to someone else, the plaintiff cannot show a “direct causal relationship” between its damages and the conspiracy, even if the injury was otherwise a foreseeable consequence of the RICO defendant’s conduct
Attorneys Fees Claim in Shareholder Derivative Case Disallowed Where Lawyers Failed to Attempt Settlement Discussions before Filing Lawsuit
In the high-stakes game of class action litigation, the lesson here is to be reasonable in trying to settle a case before litigation.
No Duty for Senior Lienholder to Search for Junior Lienholders after Real Estate Foreclosure
On foreclosure, a trustee’s duties do not include the responsibility for searching and finding all possible judgment creditors.
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