In a summary order handed down…the Court of Appeals…rejected the petitions of the SEC and Amnesty International for a rehearing en banc of the Court’s August 2015 opinion (which reaffirmed its prior ruling that a small portion of the Conflict Minerals Rule violates the First Amendment)…In its pleadings, the SEC argued that the Court of Appeals rulings…conflict with Supreme Court precedent on compelled commercial speech and expressed concern about the impact of the rulings on other SEC disclosure requirements…[I]t seems likely that the SEC will appeal the ruling to the Supreme Court…[T]here has been a lot of commentary by…NGO’s…expressing disagreement with the First Amendment ruling…[T]he rejection of the petitions for rehearing en banc is not a reason for companies to slow their…diligence efforts…While the legal challenge was underway, a number of NGO’s made it clear that they expect companies to use the very product descriptor that the Court of Appeals determined to be unconstitutional…So, even if the SEC is ultimately required to change the rule to remove that specific disclosure requirement, the NGO’s will likely continue to pressure companies to use that product descriptor…