On April 26th, the D.C. Circuit dismissed a petition seeking to invalidate the SEC's resource extractor disclosure rules. Petitioners brought constitutional and statutory challenges to the Dodd-Frank Act's requirement that certain issuers disclose payments made to foreign governments relating to the commercial development of oil, natural gas, or minerals, and the SEC's rules implementing that provision. The D.C. Circuit dismissed the petition for lack of jurisdiction. Because of the manner in which the rule was promulgated, challenges of the rule must first be brought in the federal district court. American Petroleum Institute v. SEC.