Securities Law Alert
In This Edition:• Ninth Circuit: Whistleblower Complaint Filed by a Company Insider May Constitute a Corrective
Disclosure• Second Circuit: Principal Investigator in a Clinical Trial Had a Duty Not to Trade in the Company’s
Stock• Southern District of New York: Cryptocurrency Is a “Security”• Eastern District of New York: Company Adequately Disclosed Risks of a New Software Rollout• Delaware Supreme Court: Chancery Court Did Not Err in Finding the Deal Price Was the Best Evidenceof Fair Value Despite an Imperfect Sales Process• California State Court: Federal Forum Selection Provisions for Securities Act Claims Do Not Violate
State Law
September/October 2020

Ninth Circuit: Whistleblower
Complaint Filed by a Company
Insider May Constitute a
Corrective Disclosure
Simpson Thacher“has a very experienced
and knowledgeable teamfor securities class action
defense.”– The Legal 500

On October 8, 2020, the Ninth Circuit revived
a securities fraud action that the district court
had dismissed on loss causation grounds. In
re BofI Holding Sec. Litig., 2020 WL 5951150(9th Cir. 2020) (Watford, J.). The Ninth
Circuit held plaintiffs adequately alleged thata whistleblower complaint filed by a former
employee constituted a corrective disclosurefor loss causation purposes.

Ninth Circuit Addresses theRequirements for Pleading a
Corrective Disclosure
The Ninth Circuit began by offering “a few
basic ground rules” for determining what
constitutes a corrective disclosure. First,
Simpson Thacher & Bartlett LLP

the court emphasized that “a corrective
disclosure need not consist of an admissionof fraud by the defendant or a formal findingof fraud by a government agency.” Rather,“[a] corrective disclosure can instead comefrom any source, including knowledgeable
third parties such as whistleblowers, analysts,
or investigative reporters.” Second, the court
noted that “a corrective disclosure need notreveal the full scope of the defendant’s fraud
in one fell swoop; the true facts concealedby the defendant’s misstatements may berevealed over time through a series of partial
disclosures.” Third, the court clarified that“a disclosure need not precisely mirror theearlier misrepresentation. It is enough if thedisclosure reveals new facts that, taken as
true, render some aspect of the defendant’s
prior statements false or misleading.”
The Ninth Circuit also addressed Rule9(b)’s particularity requirement as applied
to allegations of loss causation. The court
recognized that “the plaintiff will always needto provide enough factual content to give thedefendant some indication of the loss andthe causal connection that the plaintiff has
in mind.” However, the court noted that this“effort should not prove burdensome, for evenunder Rule 9(b) the plaintiff’s allegations
will suffice so long as they give the defendant
notice of plaintiff’s loss causation theory andprovide some assurance that the theory has abasis in fact.”

Unproven Whistleblower
Allegations by Insiders May
Constitute a Corrective Disclosure
Even If Not Corroborated
The Ninth Circuit found the district court
erred in determining that the whistleblower
complaint could not qualify as a corrective
disclosure because it “contained only
unconfirmed accusations of fraud” andhad not been “followed by a subsequentconfirmation of the fraud.” The Ninth Circuit
stated that in order to plead loss causation,
plaintiffs “did not have to establish that theallegations in [the whistleblower’s] lawsuit
are in fact true.” The court explained that“[f]alsity and loss causation are separate
elements of a Rule 10b-5 claim,” and notedthat plaintiffs “adequately alleged that[the company’s] misstatements were false
through allegations attributed to confidential
witnesses.” The court joined the Sixth Circuit
in rejecting a “categorical rule” that unprovenallegations cannot constitute a corrective
disclosure unless plaintiffs “identify anadditional disclosure that confirmed the truthof [those] allegations.”1
The Ninth Circuit held that “the relevant
question for loss causation purposes iswhether the market reasonably perceived[the whistleblower’s] allegations as true
and acted upon them accordingly.” In thecase before it, the court noted that thewhistleblower’s “descriptions of wrongdoing[were] highly detailed and specific, and they
[were] based on firsthand knowledge thathe could reasonably be expected to possessby virtue of his [former] position as a midlevel auditor” at the company. The court
also found it significant that the stock price1. In Norfolk County Retirement System v. Community Health
Systems, 877 F.3d 687 (6th Cir. 2017), the Sixth Circuit
held that unproven allegations could constitute a corrective
disclosure. The court reasoned that “every representationof fact is in a sense an allegation, whether made in acomplaint, newspaper report, press release, or under oath in acourtroom.”

dropped more than 30% following the filingof the complaint. The court reasoned that“[a] price drop of that magnitude would not
be expected in response to whistleblower
allegations perceived as unworthy of belief.”
The court concluded that plaintiffs adequately
alleged that the whistleblower complaint wasa corrective disclosure.
The Ninth Circuit distinguished its priordecisions in Loos v. Immersion Corp., 762
F.3d 880 (9th Cir. 2014), and Curry v.
Yelp, 875 F.3d 1219 (9th Cir. 2017). In Loos,
the court held that the announcement of agovernment investigation, standing alone,
could not constitute a corrective disclosure.2
The Ninth Circuit explained that unlike awhistleblower complaint, the announcementof an investigation “does not reveal tothe market any facts that could call into
question the veracity of the company’s priorstatements; all the market could react to was
speculation about what the investigation will
ultimately reveal.” BofI Holding Sec. Litig.,2020 WL 5951150. In Curry, the court heldthat customer complaints raising questions
about the company’s business practices
could not qualify as corrective disclosures.3
The Ninth Circuit pointed out that while
the customers in Curry had no first-handknowledge of the company’s businesspractices, the whistleblower here was “aformer insider of the company who had
personal knowledge of the facts he alleged.”

Analyses of Publicly Available
Information May Constitute
Corrective Disclosures
The Ninth Circuit affirmed the district court’s
determination that blog posts by anonymous
short-sellers analyzing publicly available
information did not constitute corrective
disclosures. However, the Ninth Circuit
made it clear that “[a] disclosure basedon publicly available information can, in
certain circumstances, constitute a corrective
disclosure.”4 The court stated that in order
2. Please click here to read our discussion of the Ninth Circuit’s
decision in Loos.
3. Please click here to read our discussion of the Ninth Circuit’s
decision in Curry.
4. The Eleventh Circuit has adopted a bright-line rule thatanalyses of publicly available information cannot constitutecorrective disclosures. See Meyer v. Greene, 710 F.3d 1189
(11th Cir. 2013) (holding that “the fact that the sources used”
in the disclosure at issue “were already public is fatal to
the [i]nvestors claim of loss causation”). The Ninth Circuit
declined to follow the Eleventh Circuit’s approach.
2

“[t]o rely on a corrective disclosure that isbased on publicly available information, aplaintiff must plead with particularity facts
plausibly explaining why the information
was not yet reflected in the company’s stock
price.” The court noted that factors thatare relevant to the analysis “include thecomplexity of the data . . . and the great effort
needed to locate and analyze it.”
The Ninth Circuit found the district court
erred in holding that plaintiffs must“allege facts explaining why other market
participants could not have done” the same
analysis of publicly available information.
“For pleading purposes,” the Ninth Circuit
stated that plaintiffs simply “needed to allege
particular facts plausibly suggesting that
other market participants had not done thesame analysis, rather than ‘could not.’”
The Ninth Circuit acknowledged that theanonymous short-seller blog posts were theproduct of “extensive and tedious research”
that arguably “provided new information
to the market.” However, the court notedthat the authors “had a financial incentive toconvince others to sell, and the posts included
disclaimers from the authors stating that they
made no representation as to the accuracy orcompleteness of the information set forth.”
The court found that “[a] reasonable investor
reading these posts would likely have taken
their contents with a healthy grain of salt.”

Judge Lee, Dissenting, Expressed
His View That It Is Unfair to Permit
Plaintiffs to Demonstrate Loss
Causation Through Unproven
Allegations
Judge Lee dissented from the majority
opinion with respect to the question ofwhether a whistleblower complaint brought

by a company insider may suffice as acorrective disclosure. He cautioned that thedecision could “have the unintended effectof giving the greenlight for securities fraud
lawsuits based on unsubstantiated assertions
that may turn out to be nothing more thanwisps of innuendo and speculation.” He
expressed his view that he would “require
additional external confirmation of fraud
allegations in a whistleblower lawsuit forthem to count as a corrective disclosure.”

Second Circuit: Principal
Investigator in a Clinical Trial
Had a Duty Not to Trade in
the Company’s StockOn September 22, 2020, the Second Circuit
affirmed the insider trading conviction ofa principal investigator in a clinical trial.
United States v. Kosinski, 2020 WL 5637600(2d Cir. 2020) (Korman, J.). The Second
Circuit found the defendant had a duty to
refrain from trading on the basis of material
nonpublic information both because he
was a “temporary insider” and because he
had a “fiduciary-like relationship” withthe company.

Principal Investigators in Clinical
Trials Are “Temporary Insiders”
The Second Circuit emphasized that “aqualifying relationship” for insider trading
purposes “does not require one to be a
traditional corporate insider.” Rather, inDirks v. SEC, 463 U.S. 646 (1983), theCourt made it clear that a duty to refrainfrom trading in company stock arises whenthird parties “have entered into a special
confidential relationship in the conduct of3

the business of the enterprise and are given
access to information solely for corporate
purposes.” Kosinski, 2020 WL 5637600(quoting Dirks, 463 U.S. 646). The Second
Circuit noted that it has “described suchindividuals as ‘temporary insiders.’” Kosinski,
2020 WL 5637600 (quoting United Statesv. Chestman, 947 F.2d 551 (2d Cir. 1991)(en banc)).

ultimately his wallet.” The court concluded
that “[a]llowing principal investigators totrade on the nonpublic inside information
entrusted to them in the course of a study
would . . . undermine that study’s integrity.”

The Second Circuit determined thatthe defendant’s “role as a principal
investigator . . . fit[s] squarely within Dirk’srecognition of ‘temporary insiders’ who play
fiduciary-like roles.” The court reasoned
that the defendant “was entrusted with [thecompany’s] information solely because of his
duty to ensure the integrity and accuracy ofthe phase three clinical trial, as well as thehealth of his patients.” The court also foundit significant that the defendant explicitly
agreed to maintain the confidentiality of theinformation the company provided and to
disclose holdings of company stock in excess
of $50,000.

In Chestman, 947 F.2d 551, the Second
Circuit stated that “[a]t the heart of thefiduciary relationship lies reliance, and defacto control and dominance.” The Kosinski
court clarified that Chestman’s “three-factor
standard . . . does not state the exclusive
test of fiduciary status, nor the proof
necessary to sustain a conviction under themisappropriation theory” of insider trading.
The Kosinski court explained that “Chestman
itself set out two other tests . . . one ofwhich is the traditional test that one acts
as a fiduciary when the business which hetransacts . . . is not his own or for his own
benefit, but for the benefit of another person,
as to whom he stands in a relation implying
and necessitating great confidence and truston the one part and a high degree of goodfaith on the other part.” The Kosinski court
found that “while the evidence here wasindeed sufficient to find that [the defendant]
owed [the company] a fiduciary duty basedon reliance, control, and dominance, that
conclusion does not signal that only suchfactors can establish a fiduciary duty for
purposes of determining insider-trading
liability.”

Principal Investigators Have a
Fiduciary-Like Relationship With
the Company
The Second Circuit further held that thedefendant’s “relationship with [the company]
was fiduciary in nature because it was a
relationship based on trust and confidence,”
memorialized in a confidentiality and stock
disclosure agreement. The court foundthat the defendant’s “trading vitiate[d] theprincipal investigator’s critical function, by
fixing his attention on his own monetary
gain and depriving the company of the
independent assessment required for
FDA approval.” The court explained thatwhen “a principal investigator’s financial
interest becomes aligned with the outcomeof the study—he has an incentive to lie
about or conceal patients’ results in order
to influence the study’s outcome, andChestman Factors Are Not
the Exclusive Standard for a
Fiduciary Relationship

Southern District of New
York: Cryptocurrency Is a
“Security”
On September 30, 2020, the Southern Districtof New York held that digital tokens (a formof cryptocurrency) constitute “securities” forpurposes of the Securities Act of 1933. SEC v.
Kik Interactive, 2020 WL 5819770 (S.D.N.Y.
Sept. 30, 2020) (Hellerstein, J.).
The court noted that “the definition of
security includes an investment contract.” Id.
(citing 15 U.S.C. § 77b(a)(1)). In SEC v. W.J.
Howey Co., 328 U.S. 239 (1946), the Supreme
Court held that “an investment contract
for purposes of the Securities Act means acontract, transaction or scheme whereby4

a person” (i) “invests his money” (ii) “in acommon enterprise” and (iii) “is led to expect
profits solely from the efforts of the promoter
or a third party.”
The court observed that “[f]ew courts in thisCircuit have had the opportunity to apply
Howey in the context of cryptocurrency,” andstated that it had “to decide this case without
the benefit of direct precedent in relation to
cryptocurrencies.” The court explained that“the definition of investment contract is a
flexible rather than a static principle, one thatis capable of adaptation to meet the countlessand variable schemes devised by those who
seek the use of the money of others on thepromise of profits.”
Because there was no dispute as to the firstelement of the Howey test (an investmentof money), the court began by considering
whether the investors participated in a“common enterprise.” The court found the“economic reality” was that the company“pooled proceeds from its sales of [the digitaltokens] in an effort to create an infrastructure
for [those tokens], and thus boost the valueof the investment.” The court held that“[t]his is the nature of a common enterprise,”because “[t]he stronger the ecosystem that[the company] built, the greater the demandfor [the digital tokens], and thus the greater
the value of each purchaser’s investment.”
The court rejected defendant’s contention
that no common enterprise existed because
the company “expressly disclaimed any
ongoing obligation to [investors] after the
distribution of their [digital tokens].” Thecourt explained that “an ongoing contractual
obligation is not a necessary requirement fora finding of a common enterprise.” The court
also found “not dispositive” “the fact that[investors] could sell their [digital tokens]
whenever they pleased.” The court noted that“the key feature is not that investors mustreap their profits at the same time; it is thatinvestors’ profits at any given time are tied
to the success of the enterprise.” The court
underscored that “[t]his is not a scenario
where the funds of each investor weresegregated and separately managed, allowing
for profits to remain independent.”
The court next considered whether theinvestment came “with a reasonable
expectation of profits to be derived
from the entrepreneurial or managerial
efforts of others.” Under Second Circuit

precedent, the court explained that it was
required to “consider whether, under all
the circumstances, the scheme was being
promoted primarily as an investment.” Id.
(quoting United States v. Leonard, 529 F.3d
83 (2d Cir. 2008)).
The court noted that “[i]n public statements
and at public events promoting [thecryptocurrency], [the company] extolled [thedigital tokens’] profit-making potential.” Thecompany’s CEO emphasized that “as demand
increased, the value of [the digital tokens]would increase, and early purchasers would
have the opportunity to earn a profit.” Thecourt found that “[t]he demand for [the digitaltokens], and thus the value of the investment,
would not grow on its own.” Rather, “[g]rowthwould rely heavily on [the company’s]
entrepreneurial and managerial efforts.”
The court concluded that the cryptocurrency
therefore “satisfies this element of the
Howey test.”

Finally, the court found meritless defendant’s
argument that the term “investment contract”
was unconstitutionally vague as applied tothe digital tokens. The court explained that
“Howey is an objective test that provides theflexibility necessary for the assessment of awide range of investment vehicles.” Although
the SEC had not “issue[d] guidance on
securities enforcement related specifically tocryptocurrencies” or brought “enforcement
actions against other issuers of digitaltokens,” the court found “the law does not
require the Government to reach out andwarn all potential violators on an individual
or industry level.”
5

Eastern District of New
York: Company Adequately
Disclosed Risks of a New
Software Rollout
On September 17, 2020, the Eastern Districtof New York dismissed a securities fraud
action alleging that a cosmetics company
and certain of its executives made material
misstatements concerning the company’s
software rollout. Lachman v. Revlon, 2020
WL 5577406 (E.D.N.Y. 2020) (Kovner, J.).
The court emphasized that “Rule 10b-5 does
not impose a blanket obligation to disclose
all information that would be material toinvestors.”
The court held that the company was not“required to advise investors of every . . . risk[of the software rollout] in order to makethe statements in its 10-K not misleading.”
The court further found that the company’s“enumeration of a number of the risks
could not reasonably be read to imply that
other risks did not exist, because the 2016
10-K made clear that enumeration of risks
was non-exclusive.”

The court also held that statements regarding
the company’s expectations regarding thebenefits of the software rollout were both“mere puffery” and “nonactionable opinion
statements.” The court explained that“[s]tatements about what a company ‘expects’
are not actionable unless” plaintiffs allege that“the expectations [did] not pan out and the
speaker did not really believe them.”
Finally, the court found that defendants’
actions “before and after the launch
undermine[d] any inference of scienter”
because the company “disclosed before the[software] rollout that the transition carried

substantial risks,” and “made abundant
disclosures [after the rollout] regarding thedisruptions that the transition had caused.”
The court found this “steady stream ofwarnings render[ed] implausible” plaintiffs’
fraud claims. The court determined that“[a]t worst, plaintiffs have established that
defendants should have been more alert andmore skeptical about the viability of [thesoftware rollout] when it was launched,” but“nothing alleged indicates that management
was promoting a fraud.”

Delaware Supreme Court:
Chancery Court Did Not Err
in Finding the Deal Price Was
the Best Evidence of Fair
Value Despite an Imperfect
Sales Process
On October 12, 2020, the Delaware
Supreme Court affirmed a Chancery Court
decision holding that the deal price was
the most reliable indicator of a metal
mining company’s fair value in an appraisal
action, even though “[t]he sale process was
not perfect.” Brigade Leveraged Capital
Structures Fund v. Stillwater Mining Co.,
2020 WL 6038341 (Del. 2020) (MontgomeryReeves, J.). The Delaware Supreme Court
further determined that the Chancery Court
did not err in declining to adjust the deal priceto account for an increase in palladium prices.
The Delaware Supreme Court explained that“fair value is just that, fair. It does not mean
the highest possible price that a company
might have sold for.”
The Delaware Supreme Court observed that
the Chancery Court “walked through eachstep of the sale process” and “found that there
were objective indicia of reliability.” While
the Delaware Supreme Court acknowledgedthat there were “fewer indicia of fairness
than [it] identified when reviewing thesales processes in DFC, Dell or Aruba, the[Chancery Court] did not abuse its discretionby determining that the objective indicia thatwere present provide a cogent foundation
for relying on the deal price as a persuasive
indicator of fair value.”55. Please click here to read our discussion of the Delaware
Supreme Court’s discussion in Aruba. (This discussion also
addresses the Delaware Supreme Court’s decisions in DFC and
Dell.)
6

The Delaware Supreme Court noted that
the Chancery Court recognized the “flaws”
in the pre-signing process, such as “thelack of Board involvement until later in thesales discussions,” but concluded that these“flaws” did “not undermine the reliability ofthe sale price.” The Delaware Supreme Court
found the Chancery Court “did not abuse its
discretion when it held that the pre-signing
process was sufficient to support relianceon the deal price as evidence of fair value,”despite the imperfections in the process.
The Delaware Supreme Court also noted that
the Chancery Court “considered and rejected”
plaintiffs’ contention that the deal price failed
to account for the increase in palladium prices
between signing and closing. The Chancery
Court found, inter alia, that “the Merger
Agreement was not designed to give thestockholders the benefit of a transaction that
included the potential upside or downsidethat would result from changes in the priceof palladium after signing.” Moreover,
the Chancery Court pointed out that if thecompany’s “stockholders had wanted tocapture the increased value of palladium, thenthey could have voted down the Merger andkept their shares.”
Because the Chancery Court “thoroughly
analyzed the facts surrounding [thecompany’s] sale in accordance with [Delaware
Supreme Court] precedent,” the Delaware
Supreme Court declined to “second-guess”
the Chancery Court’s determination that “thedeal price was a reliable indicator of [thecompany’s] fair value.”

California State Court:
Federal Forum Selection
Provisions for Securities Act
Claims Do Not Violate Federal
or State Law
On September 1, 2020, a California Superior
Court held that a federal forum provision(“FFP”) requiring Securities Act claims
to be brought in federal court is legal andenforceable under federal law and California
law. Wong v. Restoration Robotics, No.
18-civ-02609 (Cal. Super. Ct. 2020) (Weiner, J.).
The court considered the Delaware Supreme
Court’s decision in Salzberg v. Sciabacucchi,
227 A.D.3d 102 (Del. 2020), whichholds that an FFP is facially valid under
Section 102(b)(1) of the Delaware General
Corporation Law.6 The Delaware Supreme
Court compared FFPs to arbitration clauses.
But the California Superior Court foundthat “unlike an arbitration clause, the FFP
does not take away the rights of the parties
to litigate in court, or to have a jury trial,or to appeal” but merely “remove[s] theopportunity to use the different procedural
advantages of a state court forum.” The court
determined that an FFP “is most akin to acontractual forum selection clause.”
The court found that defendants had
demonstrated that the FFP was a mandatory
forum selection clause, which was “subject toshareholder vote and approval, and was notapplied retroactively.” The court determinedthat the burden of proof therefore shifted toplaintiffs to demonstrate that the clause is“unenforceable, unconscionable, unjust or
unreasonable”—and found plaintiffs failed tomeet that burden.
The court rejected plaintiffs’ contention
that state court jurisdiction of Securities
Act claims is non-waivable under Section
14 of the Securities Act. The court explainedthat such a clause “would not be legal orenforceable if [it] . . . attempted to create
jurisdiction or select jurisdiction where none
6. Section 102(b)(1) provides that a company’s certificate
of incorporation may include “[a]ny provision for the
management of the business and for the conduct of the affairsof the corporation, and any provision creating, defining,
limiting and regulating the powers of the corporation, thedirectors, and the stockholders . . . if such provisions are notcontrary to the laws of this State.” 8 Del. C. § 102(b)(1). Pleaseclick here to read our discussion of the Delaware Supreme
Court’s decision in Salzberg.
7

would otherwise exist. But Section 22 of the
Securities Act does allow federal jurisdiction
over these claims, and the FFP does not
attempt to limit the venue of any federal
district action.”
The court emphasized that the FFP causes“no disruption of the substantive rights of theshareholders to all protections provided by
the Securities Act of 1933” and impacts “onlythe procedural aspect of state versus federal
forum.” The court stated that “[t]here is noprocedural loss of Due Process, as they canpresent their federal claims to a federal court”

and “have the opportunity for discovery,
and trial by jury.” The court observed that“[t]here is even greater authority in federal
court to obtain personal jurisdiction overdefendants, and to subpoena witnesses
to trial.”
While the court dismissed claims against theissuer and its directors and officers, the court
denied motions without prejudice broughtby the underwriter and venture capital
defendants, noting that further substantiation
was needed to determine if they are entitledto the benefit of the FFP.

This edition of the
Securities Law Alert was edited by
Susannah S. Geltman
sgeltman@stblaw.com / +1-212-455-2762,
Paul C. Gluckow
pgluckow@stblaw.com / +1-212-455-2653,
Peter E. Kazanoffpkazanoff@stblaw.com / +1-212-455-3525,
and Jonathan K. Youngwood
jyoungwood@stblaw.com /+1-212-455-3539

8

New York

Los Angeles

Brooke E. Cucinella+1-212-455-3070
brooke.cucinella@stblaw.com

Joseph M. McLaughlin+1-212-455-3242
jmclaughlin@stblaw.com

Chet A. Kronenberg+1-310-407-7557
ckronenberg@stblaw.com

Paul C. Curnin+1-212-455-2519
pcurnin@stblaw.com

Lynn K. Neuner+1-212-455-2696
lneuner@stblaw.com

Palo Alto

Stephen M. Cutler+1-212-455-2773
stephen.cutler@stblaw.com

Michael J. Osnato, Jr.
+1-212-455-3252
michael.osnato@stblaw.com

Michael J. Garvey+1-212-455-7358
mgarvey@stblaw.com

Alan C. Turner+1-212-455-2472
aturner@stblaw.com

Susannah S. Geltman+1-212-455-2762
sgeltman@stblaw.com

Craig S. Waldman+1-212-455-2881
cwaldman@stblaw.com

Paul C. Gluckow+1-212-455-2653
pgluckow@stblaw.com

George S. Wang
+1-212-455-2228
gwang@stblaw.com

Nicholas S. Goldin+1-212-455-3685
ngoldin@stblaw.com

Jonathan K. Youngwood+1-212-455-3539
jyoungwood@stblaw.com

Peter E. Kazanoff+1-212-455-3525
pkazanoff@stblaw.com

David Elbaum
Senior Counsel+1-212-455-2861
david.elbaum@stblaw.com

Joshua A. Levine+1-212-455-7694
jlevine@stblaw.com
Linton Mann III+1-212-455-2654
lmann@stblaw.com

Janet A. Gochman
Senior Counsel+1-212-455-2815
jgochman@stblaw.com

Stephen P. Blake+1-650-251-5153
sblake@stblaw.com
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jkreissman@stblaw.com
Simona G. Strauss
Senior Counsel+1-650-251-5203
sstrauss@stblaw.com

Washington, D.C.
Jeffrey H. Knox
+1-202-636-5532
jeffrey.knox@stblaw.com
Cheryl J. Scarboro+1-202-636-5529
cscarboro@stblaw.com

Hong Kong
Adam Goldberg+852-2514-7552
adam.goldberg@stblaw.com

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