Mealey's (July 18, 2018, 1:59 PM EDT) -- SAN FRANCISCO — A Ninth Circuit U.S. Court of Appeals panel on July 17 ruled that Toshiba Corp. American Depositary Receipts (ADRs) are “securities” under the Securities Exchange Act of 1934, and a pension fund’s purchase of Toshiba’s ADRs on the over-the-counter market could be considered a domestic “purchase or sale of . . . any security not’ registered on a national securities exchange” pursuant to the U.S. Supreme Court’s ruling in Morrison v. National Australia Bank (Automotive Industries Pension Trust Fund, et al. v. Toshiba Cop., No. 16-56058, 9th Cir., 2018 U.S. App. LEXIS 19640)....