By Daniel Brockett, Jeremy Andersen and Christopher Barker ( October 11, 2017, 1:04 PM EDT) -- Many have commented on the fact that the U.S. Supreme Court has resolved a long-standing circuit split by holding that the class action "tolling" principle set forth in American Pipe & Construction Co. v. Utah, 414 U.S. 538 (1974), does not apply to the three-year statute of repose under the Securities Act of 1933. California Public Employees' Retirement System v. ANZ Securities Inc., 137 S. Ct. 2042 (2017). That decision, however, left open many often-thorny issues about the application of the American Pipe doctrine that have received less attention. Further, lower courts are already applying perceived lessons about timeliness to questions beyond the American Pipe question. For instance, some courts have used the decision to revisit the question of what counts as a "repose" period to begin with. This confirms that the CalPERS decision needs to considered where timeliness is an issue, even where the case has nothing to do with a Securities Act claim, and sometimes even if it has nothing to do with class action "tolling."...