On June 28, 2010, the Supreme Court granted certiorari in Janus Capital Group, Inc. v. First Derivative Traders, No. 09-525, to review a decision by the Fourth Circuit that reinstated a federal securities fraud complaint. This case presents the Court with the opportunity to address significant issues of interest to investment advisers and other professionals, including the contours of “primary” liability under Section 10(b) of the Securities Exchange Act and Rule 10b-5. See attached alert for further information.