Second Circuit: SRM Global Master Fund Ltd. P’ship v. Bear Stearns Cos.


Securities, Class Actions, Statute of Limitations, Fraud


Equitable tolling of the statute of limitations against individual claims during the period in which a class is certified is not available for claims of material misrepresentation under the securities laws, as the limiting statute is a statute of repose that creates a substantive right immune to common law equitable relief.

Insufficient proof of reliance for common law fraud claims.


SRM Global Master Fund Ltd. P’ship v. Bear Stearns Cos.