American Bar Association
Closing the Umbrella? Two Recent Second Circuit Decisions Address (and Reject) So‐Called Umbrella Liability Claims
May 2022
In late 2021, the Second Circuit issued two decisions—In re American Express Anti‐Steering Rules Antitrust Litigation (“Amex Rules”)1 and Schwab Short‐Term Bond Market Fund v. Lloyds Banking Group (“Schwab Bonds”)2—that closely analyzed and rejected so-called “umbrella” liability claims. As discussed below, these two decisions illuminate the narrow path plaintiffs face in asserting umbrella claims particularly in the Second Circuit.
得意分野
Suggested News & Insights
Sidley Represents Passport Global in Its US$425 Million Agreement to Be Acquired by Global-e (Nasdaq: GLBE)May 27, 2026May Antitrust and Competition Bulletin: Top-of-Mind Global Antitrust IssuesMay 21, 2026Sidley Represents IMA Financial Group in Equity Recapitalization TransactionMay 19, 2026Sidley Represents Rigel Pharmaceuticals in Exclusive Global License Agreement with Pfizer and Arvinas for VEPPANUMay 13, 2026Sidley Represents Private Equity at Goldman Sachs Alternatives in the Acquisition of FGI WorldwideMay 12, 2026When “The Devil Made Me Do It” Is Not a Defense: Lessons in AI Governance and Organizational Oversight from an SDNY DecisionMay 11, 2026
- Stay Up To DateSubscribe to Sidley Publications
- Follow Sidley on Social MediaSocial Media Directory
