Two years after the U.S. Court of Appeals for the Second Circuit revived investor claims against Goldman Sachs & Co. in a key case over mortgage-backed securities, the decision continues to haunt defendants—and pay dividends for MBS plaintiffs.

On Friday, investors in a mortgage-backed securities class action against JPMorgan Chase & Co. won preliminary approval for a $280 million settlement with the bank. The deal comes in one of the first cases to be affected by the Second Circuit’s September 2012 ruling in NECA-IBEW Health & Welfare Fund v. Goldman Sachs, which expanded the scope of claims that named plaintiffs can bring against MBS issuers and underwriters.

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