On July 23rd, the U.S. District Court for the District of Columbia held that the SEC's rules implementing the Dodd-Frank Act's conflict mineral disclosure requirements do not violate the Administrative Procedures Act ("APA"). In addition, the Dodd-Frank Act's provisions do not violate the First Amendment. Before it addressed plaintiff's arguments, the Court summarized the rule, providing a succinct outline of how to comply with it. The Court then noted that the Securities Exchange Act does not require the type of far-reaching cost benefit analysis advocated by plaintiffs especially where, as here, the beneficial purpose of the rule is a Congressionally-mandated humanitarian one. The Court further found that the SEC conducted a reasoned cost-benefit analysis and did not act arbitrarily or capriciously when it decided not to include a de minimis exception in its rule. Similarly, the Commission's adoption of the "reasonable country of origin inquiry" and inclusion of issuers who "contract to manufacture" was based on reasonable and permissible constructions of the Dodd-Frank Act and did not contravene the APA. National Association of Manufacturers v. SEC.