In March 2019, the Supreme Court delivered a major, and surprising, decision in Lorenzo v. Securities & Exchange Comm., 139 S. Ct. 1094 (2019). Since that decision, the lower federal courts have broadly expanded liability under Rule 10b5(a,c), first by expanding it for persons who "disseminate" false or misleading information and by breathing new life into claims based on "artifices or schemes" to defraud under Rule 10b5(a,c)