The Practical and Legal Implications of Janus for Non-Issuers- Limiting Primary Rule 10b-5 Liability for Offering Document Misstatements to the Person with Ultimate Authority over the Statement - July 2011 The Practical and Legal Implications of Janus for Non-Issuers- Limiting Primary Rule 10b-5 Liability for Offering Document Misstatements to the Person with Ultimate Authority over the Statement - July 2011