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Omissions Securities Exchange Act of 1934 Securities Litigation

Secretariat

FirstEnergy at the Sixth Circuit Reshapes Securities Class Actions

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In its landmark ruling in Owens, et al. v. FirstEnergy Corp., et al. (“FirstEnergy”), the U.S. Court of Appeals for the Sixth Circuit vacated the district court’s class-certification order, clarifying a new standard for...more

A&O Shearman

Southern District Of Florida Dismisses Securities Fraud Claim Against Equity Fund Alleging “Scheme” To Inflate Company Stock Price...

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On September 13, 2024, Judge K. Michael Moore of the United States District Court for the Southern District of Florida dismissed a complaint alleging that an equity fund (the “Company”), its affiliate companies, and several...more

A&O Shearman

Ninth Circuit Affirms Dismissal Of Exchange Act Claims Against Post deSPAC Company, Holding That Shareholders Of The SPAC Lack...

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On August 8, 2024, the United States Court of Appeals for the Ninth Circuit affirmed United States District Judge Yvonne Gonzalez Rogers’s dismissal of a putative securities class action asserting claims under Sections 10(b)...more

A&O Shearman

Second Circuit Affirms District Court’s Dismissal Of Putative Securities Fraud Class Action Against China-Based Real Estate...

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On June 10, 2024, the United States Court of Appeals for the Second Circuit affirmed the dismissal of a putative shareholders’ class action against a real estate company (the “Company”) and several of its directors (the...more

Cadwalader, Wickersham & Taft LLP

“Half-Truths,” Not “Pure Omissions”: Supreme Court Limits Section 10(b) Claims Based on Item 303 Nondisclosure to Omissions That...

On April 12, 2024, a unanimous U.S. Supreme Court issued an opinion in Macquarie Infrastructure Corp. v. Moab Partners, L.P., vacating a Second Circuit judgment that had reinstated claims under Section 10(b) of the Securities...more

Seyfarth Shaw LLP

Supreme Court Narrows Securities Fraud Exposure

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The Supreme Court recently took away an often-used weapon by shareholder plaintiffs in securities fraud cases, ruling that “pure omissions” from periodic SEC filings (absent any other duty to disclose) are not actionable...more

Cadwalader, Wickersham & Taft LLP

Securities Litigation Alert: “Half-Truths,” Not “Pure Omissions”: Supreme Court Limits Section 10(b) Claims Based on Item 303...

On April 12, 2024, a unanimous U.S. Supreme Court issued an opinion in Macquarie Infrastructure Corp. v. Moab Partners, L. P., vacating a judgment of the U.S. Court of Appeals for the Second Circuit that had reinstated claims...more

A&O Shearman

Southern District Of New York Permits Putative Class Action Against Ride Hailing Company To Proceed

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On March 14, 2024, Judge Lewis Kaplan of the United States District Court for the Southern District of New York denied defendants’ motions to dismiss a putative class action against a China-based ride hailing company, certain...more

A&O Shearman

California District Court Grants Motion To Dismiss Investor Class Action Against Lithium-Ion Battery Company

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On January 30, 2024, Judge Susan Illston of the United States District Court for the Northern District of California granted with leave to amend a motion to dismiss a putative securities class action against a battery company...more

Allen Matkins

Does The Securities Exchange Act Of 1934 Preclude Actions In State Court Under Corporations Code Section 25401?

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Section 25401 of the California Corporations Code declares generally declares unlawful to make false statements of a material fact or or omit material facts when buying or selling a security.  It is therefore similar to Rule...more

A&O Shearman

Eastern District Of New York Sustains Securities Act Claims And Dismisses Exchange Act Claims In A Putative Class Action Against...

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On September 25, 2023, Judge Pamela K. Chen of the United States District Court for the Eastern District of New York granted in part and denied in part a motion to dismiss a putative securities class action alleging that an...more

A&O Shearman

Southern District Of New York Grants Motion For Reconsideration And Motion To Dismiss Class Action Against Pharmaceutical And...

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On August 21, 2023, Judge Paul A. Crotty of the United States District Court for the Southern District of New York granted a motion for reconsideration of his denial of an earlier motion to dismiss a putative securities class...more

A&O Shearman

Eleventh Circuit Affirms Dismissal Of Putative Class Action Against Direct-To-Consumer Marketing Company For Failure To Adequately...

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On August 8, 2023, the United States Court of Appeals for the Eleventh Circuit affirmed the dismissal of a putative class action asserting claims under the Securities Exchange Act of 1934 against a direct-to-consumer...more

A&O Shearman

District Of Massachusetts Denies Motion To Dismiss Claims Based On Statements That A Lawsuit Against The Company Was “Without...

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On July 24, 2023, Judge William G. Young of the United States District Court for the District of Massachusetts granted in part, and denied in part, a motion to dismiss a putative class action brought against a software...more

A&O Shearman

Third Circuit Reverses In Part Dismissal Of Putative Class Action Against Insurance Company And Holds That The Complaint...

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On June 13, 2023, the United States Court of Appeals for the Third Circuit affirmed in part and reversed in part the dismissal of a putative class action against an insurance company (the “Company”) and certain of its...more

A&O Shearman

Who Will Get The Last Laugh? Eastern District Of Virginia Dismisses Complaint Predicated On Statements Claimed To Be An April...

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On March 14, 2023, Judge Rossie D. Alston, Jr. of the United States District Court for the Eastern District of Virginia dismissed without prejudice a putative class action against an automobile manufacturer, its U.S.‑based...more

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Southern District Of New York Dismisses Putative Class Action Against Online Sports Gaming Company For Failure To Allege...

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On January 10, 2023, Judge Paul Engelmayer of the United States District Court for the Southern District of New York dismissed with prejudice a putative class action asserting claims under the Securities Exchange Act of 1934...more

A&O Shearman

Southern District Of New York Dismisses Putative Class Action Against Beverage Manufacturer For Failure To Adequately Allege...

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On December 5, 2022, Judge Denise Cote of the United States District Court for the Southern District of New York dismissed a putative class action asserting claims under the Securities Exchange Act of 1934 against an...more

A&O Shearman

Middle District Of Florida Dismisses Putative Class Action Against Recycling Company For Failure To Adequately Allege...

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On August 4, 2022, the United States District Court for the Middle District of Florida dismissed without prejudice a putative class action asserting claims under the Securities Exchange Act of 1934 against a recycling...more

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Second Circuit Rejects SEC Request To Revisit Holding That “Scheme Liability” Requires Conduct Beyond Misstatements And Omissions

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On July 15, 2022, a panel of the United States Court of Appeals for the Second Circuit ruled against the Securities and Exchange Commission (“SEC”) in an interlocutory appeal the SEC had brought seeking to expand the scope of...more

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Central District Of California Largely Denies Motion To Dismiss Putative Class Action Regarding Proposed Acquisition Of Space...

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On July 13, 2022, the United States District Court for the Central District of California largely denied a motion to dismiss a putative class action asserting claims under the Securities Exchange Act of 1934 against a special...more

A&O Shearman

Ninth Circuit Affirms Decision Dismissing Securities Class Action Against Medical Device Manufacturer For Failure To Allege An...

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On July 7, 2022, a panel of the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal of a putative securities fraud class action against a medical device manufacturer company (the...more

Goodwin

Delaware Chancery Court Dismisses Cigna Derivative Suit Over Failed Anthem Merger

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Delaware Chancery Court Dismisses Cigna Derivative Suit Over Failed Anthem Merger; The PCAOB Sanctions Former KPMG Vice Chair Of Audit For Failure To Supervise Senior Members Of KPMG's Audit Practice; Ninth Circuit Affirms...more

A&O Shearman

Western District Of Texas Largely Denies Motion To Dismiss Putative Class Action Against Information Technology Company

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On March 30, 2022, Judge Robert Pitman of the Western District of Texas denied the majority of a motion to dismiss a putative class action asserting claims under the Securities Exchange Act of 1934 against an information...more

A&O Shearman

Northern District Of California Grants In Part And Denies In Part Class Certification Of Proposed Class Of Purchasers Of...

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On February 4, 2022, Judge Yvonne Gonzalez Rogers of the United States District Court for the Northern District of California granted in part and denied in part a motion for class certification in a putative class action...more

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