Recent Dorsey eUpdate: New Streamlined Procedure for Extension of Confidential Treatment

Public companies that have previously obtained a confidential treatment order from the Staff of the Securities and Exchange Commission for a material contract filed as an exhibit under the periodic reporting requirements of the Securities Exchange Act of 1934 must continue to file extension applications if they want to protect the confidential information from public release pursuant to a Freedom of Information Act request after the original order expires. Following the SEC’s recently adopted rules that provide a simplified approach for requesting confidential treatment as described in our recent eUpdate, the SEC’s Division of Corporation Finance has announced a streamlined procedure to extend confidential treatment for exhibits that are subject to a previously granted confidential treatment request. More information can be found in our eUpdate here:


Gary L. Tygesson

Gary is a partner in the Capital Markets and Corporate Compliance Group with extensive experience advising public companies on a wide range of securities financing, reporting and compliance matters. Gary also regularly advises clients and their Boards of Directors with respect to corporate governance, SEC compliance, public company disclosure, shareholder activism and executive compensation. Gary served as Co-Chair of the firm-wide Corporate Group from 1997 to 2002 and as a member of the Firm's Management Committee from 1997 to 2002.

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