The private right of action under Section 22 of the Commodities Exchange Act must be based on commodities transactions within the United States, the U.S. Court of Appeals for the Second Circuit held Thursday.
A divided court held that the commodities fraud claims of a Russian woman could not be heard in the United States as Judges Dennis Jacobs (See Profile) and Christopher Droney (See Profile) said the case “failed the domestic transaction test of Morrison v. National Australia Bank. Ltd., 561 U.S. 247 (2010).”
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