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Filers Eschew "Special Military Operation" In Favor Of "War", "Conflict" and "Invasion"

In a televised address February, Russian President Vladimir Putin announced a "special military operation" in Ukraine.   He later signed a law that reportedly criminalizes references to events in Ukraine as an "invasion" rather than a "special military operation".  I was therefore curious as to whether any SEC reporting issuers had adopted the preferred Russian euphemism.   In a quick search of Form 10-Q filings, I failed to find a single use of the term "special military operation".  However, I did find several references to Russia's "military action" in Ukraine.  Often these disclosures also referred to the "conflict", "invasion", or "war" in Ukraine.  In some cases, however, the situation was described simply as a "military action".   

Describing the situation in Ukraine as simply a "military action" tends to understate the number of dead and injured, the widespread property destruction and the scale of the ongoing violence in Ukraine.  

© 2010-2022 Allen Matkins Leck Gamble Mallory & Natsis LLP National Law Review, Volume XII, Number 109
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About this Author

Keith Paul Bishop, Corporate Transactions Lawyer, finance securities attorney, Allen Matkins Law Firm
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Keith Bishop works with privately held and publicly traded companies on federal and state corporate and securities transactions, compliance, and governance matters. He is highly-regarded for his in-depth knowledge of the distinctive corporate and regulatory requirements faced by corporations in the state of California.

While many law firms have a great deal of expertise in federal or Delaware corporate law, Keith’s specific focus on California corporate and securities law is uncommon. A former California state regulator of securities and financial institutions, Keith has decades of...

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