Although Gabelli arose in the context of the Investment Advisers Act of 1940, it is certain that courts will apply the ruling with equal force in actions brought under the Securities Act of 1933 and the Securities Exchange Act of 1934. The civil penalty provisions of the three acts are very similar. Compare 15 U.S.C. § 77t(d) with 15 U.S.C. § 78u(d)(3) and 15 U.S.C. § 80b-9(e). Moreover, the Supreme Court left room for courts to apply Gabelli to any case involving a government claim for civil penalties, noting that Section 2462 governs "many penalty provisions throughout the U.S. Code." Gabelli, Slip Op. at 2.