of either recklessness or conscious behavior.” Advanta, 180 F.3d at 534-35 (citations omitted). C. Statute of limitations for securities fraud claims Prior to the enactment of Sarbanes-Oxley, the statute of limitations for Exchange Act claims was the earlier of one-year after discovery of the alleged wrongdoing or three years from the occurrence of the alleged violation. See Lampf, Pleva, Lipkind, Prupis & Petigrow v. Gilbertson, 501 U.S. 350, 364, 111 S.Ct. 2773, 115 L.Ed.2d 321 (1991); NAHC, 306 F.3d at 1324 (addressing one year discovery period in 10(b) claims); G.E. Stricklin v. Ferland, 1998 WL 966023, at *4 (E.D.Pa. Nov. 10, 1998) (finding that one year/three year regime applies to Section 14(a) actions); Westinghouse Elec. Corp. v. Franklin, 993 F.2d 349, 353 (3d Cir.1993) (<HOLDING>). On July 30, 2002, Congress enacted the
holding that limitations period in section 13  214a of the code applies over limitations period for contribution actions found in section 13  204 of the code because former provision is more specific holding that for purposes of determining the appropriate limitations period section 14a actions are treated identically to actions under section 10b holding that the then twoyear statute of limitations for constructionrelated actions found in section 13  214a of the code applies over the fiveyear statute of limitations period for certain actions found in section 13  205 of the code holding that if state law provides multiple statutes of limitations for personal injury actions the general or residual statute for personal injury actions should be used for 1983 actions holding that the appropriate state statute of limitations to borrow for section 1983 actions is that for recovery of damages for personal injuries