Daniel (Dan) L. Goelzer


On April 14, 2014, the Court of Appeals for the District of Columbia Circuit upheld in part and invalidated in part the SEC’s conflict minerals rule. The court struck down, on First Amendment grounds, the portion of the rule that requires companies to identify products as “not DRC conflict free.” Specifically, the court ruled: We therefore hold that 15 U.S.C. § 78m(p)(1)(A)(ii) & (E), and the Commission’s final rule, 56 Fed. Reg. at 56,362-65, violate…