On May 2nd, the Southern District of New York partially denied defendants' motion to dismiss a Madoff feeder fund lawsuit. Plaintiffs are non-U.S. citizens who purchased privately placed interests in off-shore investment funds exclusively invested with Madoff. The Court held that at this stage of the proceedings, plaintiffs sufficiently alleged that their purchases in the investment funds occurred within the U.S. and that the Securities Exchange Act applies to plaintiffs' claims. In re Optimal U.S. Litigation.