subsidiary Arm Holdings, which helped SBG address potential classification as an “investment company” under the U.S. Investment Company Act and access U.S. investors through a Rule 144A offering. Strong investor demand, approximately four times the issuance amount, enabled SBG to secure favorable pricing and diversify its funding sources. The proceeds supported an additional $10 billion investment in OpenAI and enabled SBG to repay $40 billion in bridge financing ahead of schedule. Morrison Foerster was among the U.S. law firms advising on the landmark transaction, which highlights the importance of sophisticated legal structuring in facilitating cross-border capital markets transactions and financing major AI investments.
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