"Given that the Court emphasized a wholly separate duty applicable to investment practices -- i.e., a well-established duty to monitor investments -- it does appear that the Court opted not to recognize any continuing-violation doctrine. Similarly, given the Court's focus on the Uniform Prudent Investors Act, the application of Tibble should be limited to imprudent-investment claims, where there is a clearly established, ongoing duty to monitor, or at least those species of fiduciary claims where there is recognized duty of an ongoing nature." [Tibble v. Edison Int'l, No. 13-550 (U.S. May 18, 2015)]