Securities Class Actions: Anglo-American Comparison and Cross-Border Implications

masayuki tamaruya, Rikkyo University

Abstract

A comparative study examining English and American multi-party proceedings in the context of securities litigation. The Article compares the basic rules on multi-party proceedings and the recent developments in the two jurisdictions, and then examines their cross-border implication in view of the recent US Supreme Court decision of Morrison v National Australia Bank Ltd (2010).