Schwab Investments v. Northstar Financial Advisors, Inc.

(1) Whether a plaintiff who lacked Article III standing at the time it filed its complaint may subsequently cure this defect by later acquiring a claim or interest and then amending its complaint to allege its post-filing acquisition; and (2) whether a mutual fund's mandatory SEC disclosures may constitute a "contract" between the fund and its investors sufficient to support a private common-law breach-of-contract action against the fund distinct from other rights of action available under the federal securities laws.