Today, the U.S. Supreme Court twice took a narrow view of liability under federal law for fraudulent conduct.

In one case, the Court held that section 10(b) of the Securities Exchange Act of 1934 doesn't apply to overseas purchases and sales of securities.  That the fraud started in or affected the U.S. didn't defeat the

On Monday, the Second Circuit reversed dismissal of a securities fraud case against Smith Barney/Citigroup for misleading mutual fund investors about the true cost of "transfer agent" services, for which the mutual funds paid an outside vendor.  After a few years, the transfer agent, at SmithBarneyCitigroup's request, started rebating most of the fees to SmithBarney/Citigroup.  SmithBarney/Citigroup

Yesterday, the Supreme Court peppered Merck's lawyer with hot questions.  Before he started, at least, the advocate likely harbored hope that he could convince Their Honors that the two-year statute of limitations under 28 U.S.C. 1658(b) starts running before the plaintiff could have alleged enough facts to survive a motion to dismiss under the tough pleading standards of Bell Atl. Corp.