On November 19th, the U.S. District Court discussed whether it has jurisdiction over certain Rule 10b-5 claims asserted by the SEC against former Goldman Sachs executive Fabrice Tourre, who allegedly fraudulently structured a collateralized debt obligation offered by a Cayman Islands issuer and bought by a German bank. In an earlier order, the Court held that under Morrison v. National Australia Bank, the Court lacked jurisdiction over those claims. After the Second Circuit issued its opinion in Absolute Activist Value Master Fund Ltd. v. Ficeto, the SEC moved for relief from that order. The Court, however, denied the motion, holding that the domestic, non-fraudulent transfer of title of the instant securities was insufficiently connected with the off-shore fraudulent sale of the securities to confer Rule 10b-5 liability. SEC v. Tourre.