Credit Suisse Securities (USA) LLC v. Simmonds

Summary

The Court held that the 2-year statute of limitations for § 16(b) suits is not tolled until a § 16(a) disclosure statement is filed. The Court reasoned the statute's text starts the clock on the date profit was realized, and equitable tolling principles do not support tolling beyond when facts are discovered. The judgment was vacated and remanded for application of usual equitable tolling rules.