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International Brotherhood of Teamsters v. Daniel, 439 U.S. 551 (1979).

Recent Supreme Court decisions have illustrated a trend toward a more restrictive approach to actions brought pursuant to section 10(b)2 and rule l0b-53 of the Securities Exchange Act of 1934. International Brotherhood of Teamsters v. Daniel, in which the Supreme Court rejected an expansive reading of the securities laws, is the most recent case exemplifying this trend. The Court in Daniel refused to accept the Seventh Circuit’s determination that a noncontributory, compulsory pension plan was a "security" within the definition set forth in section 3(a)(10) of the 1934 Act.

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