Janus Extends to Corporate Insiders: Seventh Circuit | Practical Law
In Glickenhaus & Company v. Household International, Inc., the US Court of Appeals for the Seventh Circuit held that Janus Capital Group, Inc. v. First Derivative Traders, 131 S. Ct. 2296 (2011), which clarified what it means to “make” a false statement in violation of Rule 10b-5, extends not only to legally independent third parties but also to corporate insiders.