On behalf of Tremont Group Holdings, Skadden secured the dismissal with prejudice of claims arising out of Tremont's management of two offshore hedge funds that lost over $1 billion invested with Bernie Madoff. On September 21, on remand from the 2nd U.S. Circuit Court of Appeals, Judge Deborah Batts of the U.S. District Court for the Southern District of New York granted the defendants' motions to dismiss a second amended complaint filed on behalf of a putative class of hedge fund investors, ruling that the plaintiffs' claims either were precluded by the Securities Litigation Uniform Standards Act (SLUSA) or failed to state a claim under applicable Bermuda and British Virgin Islands law.