Securities and Exchange Commission v. Rio Tinto PLC

CourtDistrict Court, S.D. New York
DecidedFebruary 20, 2025
Docket1:17-cv-07994
StatusUnknown

This text of Securities and Exchange Commission v. Rio Tinto PLC (Securities and Exchange Commission v. Rio Tinto PLC) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Securities and Exchange Commission v. Rio Tinto PLC, (S.D.N.Y. 2025).

Opinion

USDC SDNY UNITED STATES DISTRICT COURT D OCUMENT SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED SECURITIES AND EXCHANGE COMMISSION, DOC #: ____ _____________ DATE FILED: __2/20/2025__ Plaintiff,

-against- 17 Civ. 7994 (AT)

GUY ROBERT ELLIOTT, OPINION & ORDER

Defendant. ANALISA TORRES, District Judge:

Plaintiff, the Securities and Exchange Commission (the “SEC”), brings this action against Defendant, Guy Robert Elliott, alleging violations of the Securities Exchange Act of 1934 (the “Exchange Act”), 15 U.S.C. § 78a et seq., and the rules promulgated thereunder, in connection with Elliott’s role as Chief Financial Officer of the Rio Tinto Group (“Rio Tinto”) and Rio Tinto’s acquisition of a coal mining enterprise in the Republic of Mozambique. See generally Compl., ECF No. 1. Elliott moves for summary judgment on the SEC’s remaining claims against him, SJ Mot., ECF No. 238, and both parties seek to exclude opinions and testimony provided by various expert witnesses, Def. Daubert Mot., ECF No. 222; Pl. Daubert Mot., ECF No. 225. For the reasons stated below, Elliott’s motion for summary judgment is denied, and the parties’ motions to exclude are denied without prejudice to renewal. BACKGROUND1 I. Rio Tinto and Its Riversdale Acquisition Rio Tinto is a large British-Australian mining company comprised of Rio Tinto plc, a public company registered in England and Wales whose shares trade on the New York Stock Exchange, and Rio Tinto Limited, a public company registered in Australia. Def. 56.1 ¶¶ 1–5,

ECF No. 256-1. Both companies are managed by a common board of directors (collectively, the “Board”). Id. ¶ 1. During the relevant period, Thomas Albanese served as Rio Tinto’s Chief Executive Officer, and Elliott served as its Chief Financial Officer. Id. ¶¶ 6–7. Both men served on the Board. Id. ¶ 9. Also throughout that time, Rio Tinto’s Group Controller’s Department (the “Controller’s Group”) was responsible for the company’s business planning and forecasting, statutory reporting, and technical accounting, which included coordinating a regular impairment review process. Id. ¶ 24. The head of the Controller’s Group reported to Elliott. Id. ¶ 15. In 2010, Rio Tinto identified Riversdale Mining Limited (“Riversdale”), an Australian mining company with assets in Mozambique’s Moatize Basin, as a possible acquisition target.

Id. ¶ 38. Rio Tinto was interested in Riversdale because the Moatize Basin was viewed as containing undeveloped sources of “metallurgical” or “coking” coal, which, unlike the coal typically burned for fuel, can be used to make steel. Id. ¶¶ 30–31, 38. That year, Rio Tinto began assessing the quantity and quality of coal at the Riversdale properties and the viability of transporting coal by rail and barge. Id. ¶ 39. Despite being informed about risks associated with the acquisition, the Board decided to acquire Riversdale in December 2010, and between April

1 The facts are taken from Elliott’s Rule 56.1 statement, the SEC’s response, and the parties’ declarations, unless otherwise noted. Disputed facts are so noted. Citations to a paragraph of Elliott’s Rule 56.1 statement include the SEC’s response. “[W]here there are no citations[,] or where the cited materials do not support the factual assertions in the [s]tatements, the Court is free to disregard the assertion.” Holtz v. Rockefeller & Co., 258 F.3d 62, 73 (2d Cir. 2001) (alteration adopted) (citation omitted). and August 2011, Rio Tinto completed the $3.69 billion purchase and changed Riversdale’s name to Rio Tinto Coal Mozambique (“RTCM”). Id. ¶¶ 41–43, 133. RTCM’s assets included three parcels of land: Benga, Zambeze, and Tete East. Id. ¶ 44. At the time of the acquisition, a mine was under construction at Benga, with coal production planned to begin in late 2011. Id. ¶ 45. An internal Rio Tinto report from that time indicates that

the company believed that Benga and Zambeze represented a “Tier One opportunit[y] in metallurgical coal,” id. ¶ 47 (quoting Def. Ex. 66 at RT_002727382), but was uncertain whether Tete East could be mined economically, id. ¶ 49. To assess RTCM’s value, Rio Tinto engaged Deloitte Touche Tohmatsu Limited, which valued the three parcels at $3.3 billion as of April 8, 2011, the date on which Rio Tinto acquired a majority interest in Riversdale. Id. ¶¶ 42, 50; Def. Ex. 71 at 2, 4. In November 2011, Rio Tinto purchased a stake in Minjova, a coal tenement adjacent to Tete East that the company also believed to contain metallurgical coal. Def. 56.1 ¶¶ 51–54; see Def. Ex. 77. Following these acquisitions, Rio Tinto commenced a mining exploration program to

assess its Mozambique assets. Def. 56.1 ¶ 57. The company also began to seriously evaluate how coal could be transported from the RTCM parcels. Id. ¶¶ 80–85. Rio Tinto knew that to develop large-scale transportation infrastructure, it would need approval from the Mozambique government. Id. ¶ 86. In September 2011, Rio Tinto provided the Mozambique government with an Environmental and Social Impact Assessment (the “ESIA”) for barging coal down the Zambezi River to the Mozambique coast. Id. ¶¶ 89–90. Two months later, Mozambique government officials told RTCM personnel that the government was “not favorable to barging on the Zambezi River” because of the associated environmental impacts and that, although the ESIA

2 Citations to “Def. Ex.” are to the attachments to Jennifer L. Conn’s declaration at ECF No. 242. was “very good,” it “fail[ed]” to “provid[e] solutions to the [environmental] problems identified.” Id. ¶ 96 (quoting Def. Ex. 98 at RT_00074947–48). Soon after, RTCM received a letter from the Mozambique government confirming that it was “not favorable” to Rio Tinto’s proposal. Id. ¶ 98 (quoting Def. Ex. 100 at RT_SEC_00077409). Despite this rejection, certain Rio Tinto employees believed that the Mozambique

government could be persuaded to accept a revised proposal and continued to strategize about how the company could secure government approval for barging. Id. ¶¶ 100, 102; Def. Ex. 101 at RT_00042021–22. In December 2011, Albanese and other Rio Tinto representatives met with the Prime Minister of Mozambique to present a public-private partnership proposal that included a modified amount of barging. Def. 56.1 ¶ 109; see Def. Ex. 10 at 86:1–21; Def. Ex. 116. In the first months of 2012, Eric Finlayson, RTCM’s managing director, shopped the proposal around to various policymakers and stakeholders. See Def. Ex. 10 at 86:1–87:6; Def. Ex. 117 at RT_00159456–57 (March 2012 Rio Tinto report describing meetings with Mozambique government officials and “engagement efforts firmly focused on restoring barging as a viable

transport option and on approvals for [Rio Tinto’s public-private partnership] proposal”); Def. Exs. 118–20, 122–23 (Rio Tinto emails from February through April 2012 describing recent meetings with Mozambique government officials to promote the proposal). In February 2012, Elliott attended a Rio Tinto Audit Committee meeting, where he learned that RTCM’s coal reserves were “significantly lower” than Riversdale reported before its acquisition, although still “significant in size and in line with market expectations for a tier one resource.” Def. 56.1 ¶¶ 155–56 (quoting Def. Ex. 154 at RT_00481103). Then, in March 2012, various media outlets reported that the Mozambique government had rejected Rio Tinto’s barging proposal. Id. ¶ 105; Def. Exs. 102–09. It was at this point that, according to Elliott’s testimony, he first learned that the Mozambique government was not favorable to barging. Def. 56.1 ¶¶ 101, 106.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Pegram v. Herdrich
530 U.S. 211 (Supreme Court, 2000)
New Hampshire v. Maine
532 U.S. 742 (Supreme Court, 2001)
Beard v. Banks
548 U.S. 521 (Supreme Court, 2006)
Laura Holtz v. Rockefeller & Co., Inc.
258 F.3d 62 (Second Circuit, 2001)
Pepsico, Inc. v. The Coca-Cola Company
315 F.3d 101 (Second Circuit, 2002)
Securities & Exchange Commission v. Collins & Airman Corp.
524 F. Supp. 2d 477 (S.D. New York, 2007)
Securities & Exchange Commission v. Espuelas
767 F. Supp. 2d 467 (S.D. New York, 2011)
Borley v. United States
22 F.4th 75 (Second Circuit, 2021)
Securities & Exchange Commission v. Espuelas
905 F. Supp. 2d 507 (S.D. New York, 2012)
Securities & Exchange Commission v. Straub
921 F. Supp. 2d 244 (S.D. New York, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Securities and Exchange Commission v. Rio Tinto PLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/securities-and-exchange-commission-v-rio-tinto-plc-nysd-2025.