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The Door for Companies to Raise Capital Through Direct Listings on Nasdaq Is Now Open

May 25, 2021

On May 19, 2021, the Securities and Exchange Commission (the “SEC”) approved Nasdaq’s proposed rule change permitting a company, at the time of its initial listing on the Nasdaq Global Select Market, to raise capital through direct listings (a “Primary Direct Listing”). The approved rules, which are similar to the NYSE's approved Primary Direct Listing rules (detailed in a December 2020 alert), are summarized in the following hyperlinked PDF.


This memorandum is a summary for general information and discussion only and may be considered an advertisement for certain purposes. It is not a full analysis of the matters presented, may not be relied upon as legal advice, and does not purport to represent the views of our clients or the Firm. David J. Johnson Jr., an O’Melveny partner licensed to practice law in California, the District of Columbia, New York, and Hong Kong, Warren T. Lazarow, an O’Melveny partner licensed to practice law in California and New York, and Jeeho Lee, an O’Melveny partner licensed to practice law in California and New York, contributed to the content of this newsletter. The views expressed in this newsletter are the views of the authors except as otherwise noted.

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