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 "author": {
  "@type": "Person",
  "name": "Wulf A. Kaal",
  "identifier": "https://orcid.org/0000-0003-0757-275X"
 },
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 "subjectOf": [
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1664809-002",
   "identifier": "kaal:claim:1664809-002",
   "text": "Congress intended the federal securities laws to cover only purchases and sales of securities that occur within the United States, a conclusion the authors reached with twenty-one law professors after reviewing the legislative history.",
   "abstract": "had intended the federal securities laws only to cover purchases",
   "citation": "Richard W. Painter, Wulf A. Kaal, Extraterritorial Application of US Securities Law – Will the US Become the Default Jurisdiction for (2010). SSRN: https://ssrn.com/abstract=1664809",
   "datePublished": "2010",
   "claim_type": "definitional",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "reading of the 1933 Act and 1934 Act legislative history"
   ],
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   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1664809-006",
   "identifier": "kaal:claim:1664809-006",
   "text": "Regardless of how the Supreme Court rules in Morrison v. NAB, Congress could overrule the holding, because the question presented is one of statutory construction and Congress may amend a statute whose interpretation it dislikes.",
   "abstract": "Congress could overrule the holding in that case because this is",
   "citation": "Richard W. Painter, Wulf A. Kaal, Extraterritorial Application of US Securities Law – Will the US Become the Default Jurisdiction for (2010). SSRN: https://ssrn.com/abstract=1664809",
   "datePublished": "2010",
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  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1664809-038",
   "identifier": "kaal:claim:1664809-038",
   "text": "European boards of directors and company lawyers should follow the Morrison decision and the section 7216 legislative process closely, prepare for the resulting changes, and ask Congress to reconsider section 7216.",
   "abstract": "European Boards of Directors and company lawyers should fol- low upcoming events closely and prepare themselves for these impending changes. They should also ask Congress to reconsider",
   "citation": "Richard W. Painter, Wulf A. Kaal, Extraterritorial Application of US Securities Law – Will the US Become the Default Jurisdiction for (2010). SSRN: https://ssrn.com/abstract=1664809",
   "datePublished": "2010",
   "claim_type": "normative",
   "confidence": "asserted",
   "is_failure_mode": false,
   "scope_conditions": [
    "pending outcome of Morrison v. NAB and of section 7216"
   ],
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  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-001",
   "identifier": "kaal:claim:1765901-001",
   "text": "Because Morrison ties Section 10(b) to the location of the securities transaction rather than to the place where the deception originated, the logic of the holding implies that the SEC likewise has no enforcement rights over securities transactions occurring outside the United States.",
   "abstract": "The logic of the holding strongly suggests that there would also be no enforcement rights for the SEC with respect to securities transactions taking place outside the United States",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "mechanism",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "Section 10(b) claims",
    "transactions executed outside the United States"
   ],
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   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-003",
   "identifier": "kaal:claim:1765901-003",
   "text": "The plaintiffs' reading that Section 10(b) covers transactions anywhere in any security of a class listed on a U.S. exchange is inconsistent with Morrison, because the opinion turns on the location of the transaction and on the holding that Section 10(b) has no extraterritorial application.",
   "abstract": "This interpretation is inconsistent with the basic thrust of the Morrison opin- ion, which focuses on the location of the transactions and the fact that Section 10(b) does not apply extraterritorially,",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "failure",
   "confidence": "argued",
   "is_failure_mode": true,
   "scope_conditions": [
    "dually listed securities",
    "transactions executed on a foreign exchange"
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   "status": "current"
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  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-004",
   "identifier": "kaal:claim:1765901-004",
   "text": "Morrison itself refutes a listing based reading of Section 10(b): the Court knew that National Australia Bank had registered and listed shares in New York, yet held that Section 10(b) did not reach trades in those ordinary shares in Australia.",
   "abstract": "The entire point of the Morrison opinion, however, is that Section 10(b) did not apply to trades in NAB's ordinary shares in Australia. This is inconsistent with a theory that the Court would apply Section 10(b) to any security listed on a U.S. exchange",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "failure",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "foreign issuers with U.S. registered ADRs or listed shares"
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   "status": "current"
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  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-007",
   "identifier": "kaal:claim:1765901-007",
   "text": "The Supreme Court should have summarized its Morrison holding in language matching the opinion's logic, namely that Section 10(b) applies only to securities bought or sold in the United States; the Court's summary language instead invited confusion.",
   "abstract": "The Supreme Court should have avoided confusion by summarizing its hold- ing in language that conforms with the logic of the opinion, which clearly supports the conclusion that Section 10(b) applies only to securities bought or sold in the United States.",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "design",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "judicial opinion drafting",
    "summary language of Morrison"
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  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-012",
   "identifier": "kaal:claim:1765901-012",
   "text": "Morrison provides no clear parameters for classifying privately negotiated transactions as domestic or foreign, because the case involved publicly traded securities and never reached the question.",
   "abstract": "There are currently no clear parameters for defining the location of privately negotiated transactions as domestic or foreign transactions under Morrison. Morrison did not explore this issue because that case involved securities that were publicly traded — in Australia.",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "failure",
   "confidence": "argued",
   "is_failure_mode": true,
   "scope_conditions": [
    "privately negotiated securities and derivative transactions"
   ],
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  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-016",
   "identifier": "kaal:claim:1765901-016",
   "text": "Treating the U.S. location of a broker as making the securities purchase domestic would circumvent most of the Morrison holding, since a foreign buyer of foreign securities could invoke U.S. law simply by routing the order through a U.S. broker.",
   "abstract": "The U.S. broker places the order based on an order from a foreign client, and U.S. securities law arguably would apply to the securities purchase, even if executed on a non-US. exchange. This line of argument would circum- vent most of the holding in Morrison.",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "failure",
   "confidence": "argued",
   "is_failure_mode": true,
   "scope_conditions": [
    "orders placed through U.S. brokers for execution on foreign exchanges"
   ],
   "source_pdf_sha256": "7b08b8a15f7d72b4eeed41be2d17c20428cb4727269077a6575c5d22e31ecdc5",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-018",
   "identifier": "kaal:claim:1765901-018",
   "text": "For exchange traded securities, the location of the exchange rather than the location of the plaintiff's broker should be the controlling factor under Morrison, although it is uncertain whether all courts will adopt this bright line test.",
   "abstract": "location of the exchange, not the location of the plaintiff's broker, should be the controlling factor, but it remains to be seen whether this bright line test will in fact be the rule adopted by all courts.",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "design",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "exchange traded securities",
    "claims analyzed under Morrison"
   ],
   "source_pdf_sha256": "7b08b8a15f7d72b4eeed41be2d17c20428cb4727269077a6575c5d22e31ecdc5",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-021",
   "identifier": "kaal:claim:1765901-021",
   "text": "Unless courts can construe Morrison for swap agreements and other derivatives consistently with both the logic and the language of the opinion, Congress will have to enact new clarifying legislation.",
   "abstract": "Unless courts can clearly construe Morrison in the context of swap agreements and other derivative securities, in a manner that is consistent with the logic as well as the language of the Court's opinion, Congress will have to enact new legislation that clarifies this issue.",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "condition",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "derivative transactions with extraterritorial components"
   ],
   "source_pdf_sha256": "7b08b8a15f7d72b4eeed41be2d17c20428cb4727269077a6575c5d22e31ecdc5",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/1765901-026",
   "identifier": "kaal:claim:1765901-026",
   "text": "Foreign-cubed rulings such as Morrison determined the size of the plaintiff class in private suits, but were irrelevant to the SEC's ability to enforce wherever a U.S. securities transaction is connected to the alleged fraud.",
   "abstract": "Morrison and other foreign-cubed cases determined the size of the plaintiff class in private suits, an issue relevant to the compensation of plaintiffs' lawyers, but the rulings in these cases were irrelevant to whether the SEC could pursue enforcement",
   "citation": "Kaal and Painter, The Aftermath of Morrison v. National Australia Bank and Elliott Associates v. Porsche (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1765901",
   "datePublished": "2011",
   "claim_type": "condition",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "private class actions compared with SEC enforcement"
   ],
   "source_pdf_sha256": "7b08b8a15f7d72b4eeed41be2d17c20428cb4727269077a6575c5d22e31ecdc5",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-001",
   "identifier": "kaal:claim:2029983-001",
   "text": "After Morrison, parties to securities transactions can be confident that U.S. law will not apply in private suits so long as their transactions are definitively located outside the United States, a certainty that did not exist under the prior conduct and effects tests.",
   "abstract": "after Morrison transacting parties can be confident that U.S. law will not apply in private suits provided their transac- tions are definitively outside the United States.",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "condition",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "private lawsuits, not SEC or DOJ enforcement",
    "transaction location is unambiguous"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-005",
   "identifier": "kaal:claim:2029983-005",
   "text": "Because Morrison limits U.S. securities law to transactions inside the United States, plaintiffs' attorneys are predicted to look increasingly to European countries and other venues in which to file securities class actions and similar suits.",
   "abstract": "As a result of the Morrison decision, limiting application of U.S. securities laws to transactions inside the United States, plaintiffs' attorneys may increasingly look to European coun- tries and other venues to file securities class actions and simi- lar suits.",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "predictive",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "holds for private securities class actions after Morrison"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-010",
   "identifier": "kaal:claim:2029983-010",
   "text": "Defined geographic borders for securities transactions, the overarching assumption behind Morrison, are an unstable basis for limiting the extraterritorial reach of either private litigation or government regulation.",
   "abstract": "Defined geographic borders for securities transactions—the overarching assumption behind the Morrison decision—are an unstable basis for limiting the extraterritorial reach of both private litigation and government regulation.",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "failure",
   "confidence": "argued",
   "is_failure_mode": true,
   "scope_conditions": [
    "securities transactions whose location is contestable",
    "applies to both private suits and regulatory enforcement"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-021",
   "identifier": "kaal:claim:2029983-021",
   "text": "The Dutch unfair trade practice and misrepresentation provisions invoked in Fortis, taken together, approximate the legal protections available in the United States under Section 10(b) and Rule 10b-5, which makes the Dutch legal system a possible avenue for circumventing the restrictions imposed by Morrison.",
   "abstract": "Combined, these sections approximate legal protections available in the United States under Section 10(b) and Rule 10b-5. Given the comparability, the Dutch legal system could present a possible avenue for circumventing the restrictions imposed by the Morrison decision.",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "mechanism",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "claims brought under Dutch civil law and the Dutch Financial Supervision Act"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-030",
   "identifier": "kaal:claim:2029983-030",
   "text": "Canada could engage in Forum Competition with the United States if its courts allow suits under Canadian law over all transactions in securities listed for trading in Canada, even transactions executed in the United States, assembling a class of Canadian and U.S. investors that Morrison forbids in U.S. courts.",
   "abstract": "Canada thus has an opportunity to engage in Forum Competition with the United States if its courts assume a different posture and allow suits under Canadian law with respect to all transactions in securities listed for trading in Canada, even if some of those transactions take place in the",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "condition",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "Canadian courts adopt a posture different from U.S. courts applying Morrison"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-031",
   "identifier": "kaal:claim:2029983-031",
   "text": "Morrison's transactional test could prove relatively short lived because it is rooted in geography while an increasing number of securities transactions defy geographical boundaries.",
   "abstract": "The transactional test in Morrison could be relatively short lived because it is rooted in geography and an increasing num- ber of securities transactions defy geographical boundaries.",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "predictive",
   "confidence": "argued",
   "is_failure_mode": true,
   "scope_conditions": [
    "transactions off organized exchanges and on exchanges that cross borders"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-033",
   "identifier": "kaal:claim:2029983-033",
   "text": "The authors propose a rule under which, unless a transaction is unambiguously inside the United States, the transaction is not inside the United States if the parties have expressly stated that intent; this can be harmonized with both Morrison and the existing statutory framework.",
   "abstract": "rule would stipulate that unless a transaction is unambiguous- ly inside the United States, the transaction does not take place inside the United States if the parties have expressly stated their intent that it does not take place inside the United States.",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "design",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "geographically ambiguous transactions only",
    "does not apply to transactions unequivocally inside the United States"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-036",
   "identifier": "kaal:claim:2029983-036",
   "text": "U.S. courts have only a limited capacity to integrate parties' choice of law into a post-Morrison regime for defining transaction location, and adding variables raises the risk of inconsistent case law across districts and circuits.",
   "abstract": "The complexities in the above discussion suggest, however, that U.S. courts have a limited capacity to integrate choice of law into a post-Morrison regime defining transaction location.",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "failure",
   "confidence": "argued",
   "is_failure_mode": true,
   "scope_conditions": [
    "absent a clear mandate in Morrison and given the statutory bar on opting out"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  },
  {
   "@type": "Claim",
   "@id": "https://wulfkaal.github.io/claims/2029983-038",
   "identifier": "kaal:claim:2029983-038",
   "text": "Choice of law should replace the geographically based transactional test in those circumstances where geography is ambiguous.",
   "abstract": "In sum, choice of law should replace the geographically- based transactional test in those circumstances where geogra- phy is ambiguous.",
   "citation": "Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983",
   "datePublished": "2012",
   "claim_type": "normative",
   "confidence": "argued",
   "is_failure_mode": false,
   "scope_conditions": [
    "limited to transactions whose geographic location is ambiguous"
   ],
   "source_pdf_sha256": "fde2ff611420eb283cbb49a6b681a2ae8efa2b4603ae71480e2d91483f0295f2",
   "status": "current"
  }
 ],
 "description": "21 claims in the published works of Wulf A. Kaal carry the concept tag 'morrison'. Derived node: a roster, not an adjudicated definition."
}