Skadden secured the dismissal of claims that Bank of America Corporation aided and abetted fraud by Herbalife, LTD by providing a line of credit to the company, in which the plaintiff purchased a short position under the assumption its business would collapse. On January 21, Judge Louis L. Stanton of the U.S. District Court for the Southern District of New York held that Bank of America owed the plaintiff no duty to refrain from assisting Herbalife and that he knowingly and voluntarily risked any injury that he suffered.

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