On March 10, 2014, the Supreme Court granted certiorari in Public Employees' Retirement System of Mississippi v. IndyMac MBS Inc., No. 13-640, to examine the impact of the class action tolling rule it previously recognized in American Pipe & Construction Co. v. Utah, 414 U.S. 538 (1974), on the three-year repose period under Section 13 of the Securities Act of 1933.