In the case of Blue Chip Stamps v. Manor Drug Stores, 1974, the U.S Supreme Court established a rule regarding standing in securities fraud cases. The court held that only actual purchasers or sellers of securities have standing to file private damage claims under Section 10(b) and Rule 10b-5 of the Securities Exchange Act of 1934. This ruling is commonly known as "the purchaser-seller rule." In this particular case, Manor Drug Stores alleged that they were induced not to sell their shares in Blue Chip Stamps due to misleading statements made by the company's management about an upcoming reorganization plan. However, since Manor Drugs did not actually buy or sell any shares based on these allegedly fraudulent statements, they lacked standing according to this new rule set forth by the court.

In the dissenting opinion for Blue Chip Stamps v. Manor Drug Stores, Justice White disagreed with the majority's interpretation of Rule 10b-5 and its application to potential investors who decided not to invest due to fraudulent misrepresentation. He argued that there is no explicit language in Section 10(b) or Rule 10b-5 limiting their scope only to actual buyers or sellers of securities. Instead, he believed that these provisions should protect all individuals who suffer harm as a result of deceptive practices related to securities transactions - including those misled into retaining or not acquiring shares. Furthermore, he contended that this broader interpretation was more consistent with Congress' intent when it enacted the Securities Exchange Act: namely, maintaining public confidence in financial markets by deterring fraud and manipulation. Lastly, Justice White expressed concerns about judicial overreach and cautioned against courts making policy decisions better left to legislative bodies.