Margaret Sachs's article cited by the U.S. Supreme Court
In its opinion in Morrison v. National Australia Bank, the U.S. Supreme Court cited with approval critiques of the prevailing approach to the extraterritoriality of Rule 10b-5, including that of Robert Cotten Alston Chair in Corporate Law Margaret V. Sachs in "The International Reach of Rule 10b-5: The Myth of Congressional Silence" (28 Colum. J. Trans. L. 677 (1990)). Writing for the Court, Justice Scalia noted that Sachs challenged the assumption on which the prevailing approach rested - namely, that the Congress that enacted the Securities Exchange Act lacked awareness of internationalized securities markets.