Ninth Circuit Affirms Dismissal of Securities Class Action on Materiality and Safe Harbor Grounds

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The U.S. Court of Appeals for the Ninth Circuit upheld a district court’s dismissal of a securities fraud class action suit, ruling that defendants’ alleged incomplete disclosures were not material omissions and that the issuer’s earnings projections fell within the statutory safe harbor under the Private Securities Litigation Reform Act (PSLRA). In the process, the court clarified case law within that circuit on the application of the PSLRA safe harbor provisions.

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