In 1968, the Second Circuit decided "Schoenbaum vs Firstbrook," a doctrinally significant case for two reasons. The initial panel decision found, among other things, that the allegedly fraudulent mismanagement of a foreign company had sufficient effects in the US to trigger the assertion of US subject matter jurisdiction. It is argued that as a result of the forces creating an internationalized securities marketplace, the prevailing extraterritoriality doctrine has become both useless and problematic.

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