Communication with Financial Analysts and Related Disclosure Issues

November 1, 2007

Attached is a memorandum we recently updated that discusses the range of investor and analyst communication issues faced by public companies. It reflects recent developments in the application of Regulation FD as well as in the judicial treatment of the duty to update. The memorandum also discusses, among other topics, responding to market rumors, entanglement with research reports and public disclosure of non-GAAP financial measures.

Please feel free to call any of your regular contacts at the firm or any of our partners and counsel listed under Capital Markets in the Practice Area section of this website if you have any questions.