A US Court of Appeals for the Second Circuit panel affirmed Wells Fargo’s motion to dismiss a suit by a broker dealer claiming breach of a partnership agreement. Williams Trading LLC referred customers to a newly created options trading desk at Wells Fargo and received a percentage of the trading desk’s net revenues in return, an arrangement it described as a joint venture. Williams alleged Wells Fargo wrongly made trades with the firm’s own money, as opposed to its customers’ money, after specifically denying an interest in proprietary trading. The panel found that the agreement did not qualify as a joint venture in part because Williams did not share Wells Fargo’s risk of loss, and affirmed a district court’s April grant to dismiss. David Bohan and Emily Stern represented Wells Fargo in this matter. (“Wells Fargo Didn’t Breach Partnership Deal, 2nd Circ. Says,” January 28, 2014)