1. The Second Circuit Adopts a Business Purpose Test for Going Private: Marshel v. AFW Fabric Corp. and Green v. Santa Fe Industries, Inc.
2. Papf, Karl Ernst or Ernst
3. 20A of the Exchange Act, but observes that Section 20A was added to the securities laws in 1988 (citing Lampf, 501 U.S. at 361). In Herman & MacLean, 459 U.S. at 380 n. 8, the Court identified six express private rights (citing Securities Act. � � 11, 12, 15, 15 U.S.C. � � 77k, 77l, 77o; Exchange Act;The Supreme Court has been inconsistent in its count of contemporaneous express private rights in the Exchange Act. Musick Peeler, 508 U.S. at 296, lists eight express liability provisions, Sections 11, 12, and 15 of the Securities Act, and Sections 9