Janus Capital Group v. First Derivative Traders
Citation
564 U.S. 135 (2011)
Facts
Stub — to be completed.
Issue
Stub — to be completed.
Holding
Stub — to be completed.
Rule
Only the “maker” of a statement — the person with ultimate authority over the statement’s content and whether/how to communicate it — can be primarily liable for a misstatement under Rule 10b-5(b).
Significance
Narrowed primary liability by limiting “maker” to those with ultimate control; investment advisers who draft statements for funds they manage are not “makers.”