Expect Focus, Vol. I, Winter 2009 reported on the decision of the Second Circuit Court of Appeals in W.R. Huff Asset Management Co. v. Deloitte & Touche LLP, holding that an investment adviser lacked constitutional standing to sue on behalf of its clients. On April 20, 2009, the U.S. Supreme Court declined to review the Second Circuit’s decision. In W.R. Huff, an investment adviser brought suit against firms that provided underwriting, auditing, and legal services to a bankrupt corporation in which its clients had invested. The adviser argued that its standing to sue stemmed from its power to make investment decisions for its clients and from a power-of-attorney in which its clients authorized the lawsuit. The Supreme Court denied certiorari despite the adviser’s claim that a majority of district courts supported standing under such circumstances.