Forward-Looking Statements Held Non-Actionable Under Federal Securities Law

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Plaintiff brought claims for federal securities fraud against defendants, alleging that defendants made false and misleading statements in a business plan which contained projections which were presented to prospective investors in a natural gas development. Plaintiff alleged that defendants used the projections to entice investors but never intended to take steps to effectuate the projections. The lower court granted defendants’ judgment as a matter of law after a trial, finding that plaintiff failed to show reliance on any material misrepresentation made by defendants.

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