Author: Adam Lurie

Ninth Circuit Holds that Rule 10b-5 Could Apply to Unsponsored ADRs Traded Over the Counter

July 2018 Ninth Circuit Holds that Rule 10b-5 Could Apply to Unsponsored ADRs Traded Over the Counter     Contents   OTC Markets Are Not Domestic Exchanges. 2 Transactions in Unsponsored ADRs Can Be Domestic Transactions. 2 Rejection of Parkcentral 2 Sufficiency of Claims Against Toshiba. 2   In a ruling that potentially expands antifraud liability for non-U.S. issuers, the Ninth Circuit Court of Appeals recently held that sales of unsponsored American Depositary Receipts (“ADRs”) tr