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Case 22-1426, Document 79, 06/29/2023, 3536060, PageS0 of 93 37 The reach of the 2003 amendment to Section 3283 is clear. Because Congress has expressly extended the statute of limitations to pre-enactment conduct, Judge Nathan correctly resolved this analysis at Landgraf step one. In the alternative, however, the statute is— at worst—ambiguous. If the Court takes that view, it should proceed to Landgraf step two, which examines the retroactive effects of the statute. ii. Landgraf Step Two As the Supreme Court explained in Landgraf, “le]ven absent specific legislative authorization,” ap- plying a statute to pre-enactment conduct “is unques- tionably proper in many situations.” 511 U.S. at 273. “A statute does not operate ‘retrospectively’ merely be- cause it is applied in a case arising from conduct ante- dating the statute’s enactment, or upsets expectations based in prior law.” Id. at 269. Instead, the question is whether the statute “would impair rights a party pos- sessed when he acted, increase a party’s liability for past conduct, or impose new duties with respect to transactions already completed.” Jd. at 280. Im- portantly, “the fact that a new procedural rule was in- stituted after the conduct giving rise to the suit does not make application of the rule at trial retroactive,” because parties have “diminished reliance interests in matters of procedure” and “[b]ecause rules of proce- dure regulate secondary rather than primary con- duct.” Id. at 275. In Vernon v. Cassadaga Valley Cent. School Dist., 49 F.3d 886 (2d Cir. 1995), this Court considered a new statute of limitations that shortened the time to file DOJ-OGR-00021697