In Loginovskaya v. Batratchenko, 764 F.3d 266 (2d Cir. 2014) (No. 13-1624), plaintiff, a Russian citizen, brought claims under the Commodities Exchange Act (CEA), 7 U.S.C. § 1, et seq., alleging that while in Russia, defendants fraudulently induced her into investing in a New York corporation. The district court dismissed the case, and the Second Circuit affirmed. The court first noted that the CEA was silent on its extraterritorial effect and, drawing upon decisions relating to § 10(b) of the Securities Exchange Act of 1934, held that the CEA applied only to domestic commodities transactions. The court then rejected plaintiff’s argument that she had sufficiently alleged a domestic transaction because she wire-transferred her funds to defendant’s bank account in New York. The court ruled that the wire transfer was merely the action needed to carry out the transaction, and not the transaction itself, and thus was insufficient to demonstrate a domestic transaction. The court found that because the parties undisputedly negotiated, reached a meeting of the minds, and executed the contracts in Russia, plaintiff could not establish a domestic commodities transaction and, therefore, could not state a claim under the CEA.