On August 14th, the Second Circuit Court of Appeals affirmed the dismissal of plaintiff's federal and state claims of market manipulation based upon the practice of placing "support bids" in the Auction Rate Securities ("ARS") market and claims of negligent misrepresentation based upon the credit ratings assigned to the ARS at issue. The Court holds that the market manipulation claims fail because Merrill Lynch's website disclosures contained sufficient information to preclude a market manipulation claim. And plaintiff's negligent misrepresentation claims against the ratings agencies fail to state a claim under New York law. The Anschutz Corp. v. Merrill Lynch & Co., Inc.