The following excerpt is from Washington Public Power Supply System Securities Litigation, In re, 823 F.2d 1349 (9th Cir. 1987):
22 Cf. In re New York City Municipal Securities Litigation, 507 F.Supp. 169, 187-88 (S.D.N.Y.1980) (no private right of action against municipality).
1 The private right of action was first recognized in Osborne v. Mallory, 86 F.Supp. 869 (S.D.N.Y.1949).
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