UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Similar documents
Second Circuit Holds That PSLRA s Safe Harbor Provisions Shield American Express from Liability

Case 4:17-cv HSG Document 59 Filed 09/25/18 Page 1 of 8 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Latham & Watkins Corporate Department. The Lessons of Slayton v. American Express for Forward-Looking Statements

United States District Court

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

v. JURY TRIAL DEMANDED

Case 3:15-cv EMC Document 88 Filed 08/02/16 Page 1 of 30 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA I.

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS FAYETTEVILLE DIVISION CASE NO. 12-CV-5162 ORDER

Revisiting Affiliated Ute: Back In Vogue In The 9th Circ.

The SEC Pleading Standard For Scienter

Case 1:01-cv SSB-TSH Document 22 Filed 02/10/2004 Page 1 of 13

Case 1:14-cv JSR Document 461 Filed 02/19/16 Page 1 of 13

Case 8:07-cv AG-MLG Document 68 Filed 03/09/2009 Page 1 of 7

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA. Plaintiff, Defendants.

Case 3:16-cv JST Document 56 Filed 02/08/17 Page 1 of 9 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES GENERAL

FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

This is a securities fraud case involving trading in commercial mortgage-backed

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge R. Brooke Jackson ORDER

The Near Impossibility of Pleading Falsity of Opinion Statements Under Section 10(b) of the Securities Exchange Act and Rule 10b-5

Case 1:13-cv KBF Document 26 Filed 06/24/13 Page 1 of 9

Case 1:13-cv KBF Document 28 Filed 06/24/13 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. x ) ) ) ) ) ) ) ) ) x

United States Court of Appeals For the Eighth Circuit

Broadening the Protections for Forward-Looking Statements

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND SOUTHERN DIVISIO N

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA. Plaintiff,

Case: , 08/17/2017, ID: , DktEntry: 57-1, Page 1 of 12 NOT FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Order Code RS22038 Updated May 11, 2005 CRS Report for Congress Received through the CRS Web Securities Fraud: Dura Pharmaceuticals, Inc. v. Broudo Su

Case 1:09-md PKC Document 538 Filed 04/12/12 Page 1 of 25

Case 3:17-cv VC Document 55 Filed 07/31/17 Page 1 of 5 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case 2:07-cv MJP Document 78 Filed 04/18/2008 Page 1 of 17 UNITED STATES DISTRICT COURT

Case 1:13-cv RHB Doc #14 Filed 04/17/14 Page 1 of 8 Page ID#88

Case 3:01-cv SI Document 1478 Filed 09/02/2008 Page 1 of 14 BACKGROUND

Defendants. x. of the Securities Exchange Act of 1934 (the Exchange Act ), 15 U.S.C. 78j(b) and 78t(a),

DECISION AND ORDER. System ("Fulton County"), Wayne County Employees' Retirement System ("Wayne

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Case 2:16-cv RSM Document 74 Filed 06/14/17 Page 1 of 15 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE I.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. Case CIV-WPD ORDER GRANTING IN PART AND DENYING IN PART MOTION TO DISMISS

Case 3:16-cv SI Document 122 Filed 10/26/16 Page 1 of 23 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

The Challenges For CEA Price Manipulation Plaintiffs

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Plaintiffs, MEMORANDUM v. OPINION AND ORDER INTRODUCTION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

Second Circuit Confirms that Statements of Opinion Need Not Be Accompanied by Disclosure of All Underlying Conflicting Information

Post-Halliburton II Update: Eighth Circuit Denies Class Certification Based on Lack of Price Impact

Case: 3:09-cv slc Document #: 40 Filed: 11/24/2009 Page 1 of 38 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN

Tellabs and Pleading a Strong Inference of Scienter: Is a New Split Emerging over its Application in Private Securities Litigation?

Case 4:08-cv LLP Document 73 Filed 06/09/10 Page 1 of 27 PageID #: 785 UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA INTRODUCTION

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Case 2:10-cv ADS-WDW Document 86 Filed 12/10/13 Page 1 of 18 PageID #: 1987

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

Civil RICO Liability - The Second Circuit's Interpretation of the PSLRA Amendment has Broad Implications for Victims of Securities Fraud Conspiracy

Case 4:05-cv RP-TJS Document 40 Filed 07/07/2006 Page 1 of 42

DETECTING, INVESTIGATING & DOCUMENTING FRAUD PART ONE

In the United States Court of Appeals for the Second Circuit

Case 9:17-cv RLR Document 91 Entered on FLSD Docket 04/30/2018 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case 3:13-cv BEN-RBB Document 44 Filed 10/24/13 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT. Nos &

Case 2:06-cv JCC Document 51 Filed 12/08/2006 Page 1 of 10 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE

Case 1:17-cv PAC Document 37 Filed US DCS e 1 of 15 ELECTRONICALLY FILED DO C #: UNITED STATES DISTRICT COURT : SOUTHERN DISTRICT OF NEW YORK

Physician s Guide to the False Claims Act - Part I

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

Case 1:14-cv WHP Document 103 Filed 08/23/17 Page 1 of 7

Case 1:13-cv RJS Document 34 Filed 05/13/14 Page 1 of 18 ) ) ECF CASE ) )

Case 2:15-cv JAK-AJW Document 26 Filed 07/07/15 Page 1 of 6 Page ID #:233

Case 3:15-md CRB Document 3392 Filed 06/28/17 Page 1 of 18 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case 1:15-cv JMF Document 121 Filed 08/01/17 Page 1 of 14. : : Plaintiff, : :

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

x IN RE GLG LIFE TECH CORPORATION SECURITIES LITIGATION

Case 1:16-cv ER Document 38 Filed 02/15/17 Page 1 of 14

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA. Plaintiff, Defendants. Plaintiff, Defendants.

150 Spear Street, Suite 1800

Case 1:08-cv BSJ-THK Document 95 Filed 06/10/2010 Page 1 of 19

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER

CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL ====== PRESENT: THE HONORABLE S. JAMES OTERO, UNITED STATES DISTRICT JUDGE

Case 4:18-cv HSG Document 38 Filed 07/23/18 Page 1 of 7 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

NOT FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Eighth Circuit Interprets Halliburton II

MEMORANDUM OPINION. Thomas J. McKenna Gregory M. Egleston GAINEY MCKENNA & EGLESTON Attorneys for Lead Plaintiff

T he Supreme Court s 2015 decision in Omnicare,

OPINION AND ORDER. Securities Class Action Complaint ("Complaint") pursuant to Rules 9(b) and 12(b)(6) of the

Case 1:07-cv PLF Document 212 Filed 03/31/17 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

United States Supreme Court Limits Investor Suits for Misleading Statements of Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION ORDER APPOINTING LEAD PLAINTIFF AND APPROVING LEAD AND LIAISON COUNSEL

Case , Document 53-1, 04/10/2018, , Page1 of 19

: : : : : : : : : : : : : : 15cv3781

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION : : : : : : : : : : ORDER

Case 4:08-cv Document 68 Filed in TXSD on 07/09/09 Page 1 of 74 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Latham & Watkins Litigation Department Securities Litigation and Professional Liability Practice

Case3:10-cv SI Document235 Filed05/24/12 Page1 of 7

DURA PHARMACEUTICALS v. BROUDO: THE UNLIKELY TORT OF SECURITIES FRAUD

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SECURITIES LITIGATION & REGULATION

Transcription:

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA UNION ASSET MANAGEMENT HOLDING AG, et al., v. Plaintiffs, SANDISK CORP., et al., Defendants. Case No. 15-cv-01455-VC ORDER GRANTING MOTION TO DISMISS AND INVITING MOTIONS TO RECONSIDER ORDER APPOINTING LEAD PLAINTIFFS Re: Dkt. Nos. 74, 86 SanDisk's motion to dismiss is granted, and the complaint is dismissed with leave to amend. Additionally, the Court invites interested plaintiffs to file motions to reconsider its prior order appointing the current lead plaintiffs. I. Under the PSLRA's "safe harbor," a "forward-looking statement" is not actionable as long as it is identified as forward-looking and "is accompanied by meaningful cautionary statements identifying important factors that could cause actual results to differ materially" from predicted results. 15 U.S.C. 78u-5(c)(1)(A)(i). The "meaningful cautionary statements" requirement is, in reality, quite forgiving: for example, it is enough to warn investors about "certain risks and uncertainties" that are "described in detail in the company's [SEC] filings." Police Ret. Sys. of St. Louis v. Intuitive Surgical, Inc., 759 F.3d 1051, 1059 (9th Cir. 2014) (alteration in original). The vast majority of the allegedly fraudulent statements identified in the complaint concern "financial projections," or "plans and objectives of management for future operations," or "future economic performance," or "the assumptions underlying or related to any of these issues," and are therefore forward-looking. No. 84 Emp'r-Teamster Joint Council Pension Trust

Fund v. Am. W. Holding Corp., 320 F.3d 920, 936 (9th Cir. 2003). For example: "[W]e are increasing our full-year non-gaap gross margin range to 47% to 49%, up from our previous forecast of 45% to 48%, reflecting continued strengthening of our product mix." Complaint 21. "I project that SanDisk revenue from enterprise SSDs will exceed $1 billion in 2016 time frame.... Our goal is to become a number one market share leader in enterprise SSDs by 2017 time frame." Complaint 24. "I think over time, you'll see a shift maybe from SATA in particular to PCIe.... I think we will see a trend over the next couple of years where we're replacing SATA applications with PCIe and SAS." Complaint 26. "[The] best is yet to come for SanDisk." Complaint 27. "[O]ur goal is that from enterprise solution sales, we want to grow this to $1 billion-plus of revenue in 2016 timeframe. And by 2017 timeframe, we want to be a clear, number one market shareholder of all enterprise SSD business." Complaint 31. "Fusion-io will accelerate our efforts to enable the flash-transformed data center.... Customers will benefit from the addition of Fusion-io's leading PCIe solutions to SanDisk's vertically integrated business model." Complaint 33. "Fusion-io's innovative hardware and software solutions will be augmented by SanDisk's worldwide scale and vertical integration." Complaint 33. "With the addition of Fusion-io's PCIe hardware and software solutions, SanDisk will have the broadest enterprise flash solution portfolio in the industry.... At the same time, SanDisk's integration model will further enhance the quality, performance and reliability of these enterprise solutions while providing customers with valuable continuity of supply." Complaint 34. "[W]e expect to generate synergies related to revenue, cost of goods sold, and expenses. In terms of revenue, the acquisition of Fusion-io will accelerate our ability to grow in the enterprise market, with the broadest SSD solutions portfolio in the industry, applied 2

across a broader customer base." Complaint 34. "[W]e look forward to growing our business aggressively in, and at a fast pace in the enterprise storage market." Complaint 35. "[W]e had talked about $1 billion-plus of enterprise solution revenue in 2016 timeframe. With the acquisition of Fusion-io, we certainly believe we will be able to accelerate that opportunity. In fact, we think we will reach the $1 billion-plus target with this acquisition in 2015." Complaint 36. "[T]his does accelerate the opportunity for us in enterprise SSD, in terms of reaching our goal of $1 billion of revenue." Complaint 37. "[W]e are very excited about the Fusion-io opportunity and believe that it will help us to continue to deliver very strong profits, as is indicated in our target financial model." Complaint 37. "[The acquisition of Fusion-io] will accelerate our transformation into a value added solutions provider and will further enhance our capabilities with new solutions, channels, customers and go-to-market expertise." Complaint 46. "[SanDisk is] on an excellent path to deliver yet another year of record results." Complaint 46. "For our third quarter, we expect the strongest sequential growth to come from our embedded products, including both inand and custom embedded solutions." Complaint 49. "[W]e expect the Fusion-io acquisition to close in our third fiscal quarter.... We continue to expect the acquisition to be accretive to our non-gaap earnings in the second half of our FY2015." Complaint 49. "This portfolio, coupled with our broad and expanding customer reach and wellestablished vertical integration capabilities, positions us well to accelerate our momentum in the fast-growing market for enterprise Flash. We expect our enterprise SSD revenue to surpass $1 billion in 2015, a year ahead of our previously stated timeline." Complaint 3

55. "I will now turn to forward-looking commentary. For the fourth quarter we have strong demand signals from our customers in all key product categories.... [W]e expect to be in supply allocation and this will constrain our growth in some areas in Q4. We will prioritize our business according to our strategic priorities and customer relationships." Complaint 57. "[W]e expect that 2014 will be another record year in both revenue and earnings." Complaint 57. "[W]e will work hard in the fourth quarter to meet the needs of our customers and service the demand out there.... [W]e will work very closely with [our customers] and that demand will not go away for SanDisk." Complaint 58. "[W]e see strong demand in all product categories for our business in 2015 timeframe, and SanDisk's focus will continue to be to have the best mix in terms of high-value solutions in our revenue." Complaint 59. "[W]e expect that our revenues in this business are going to exceed $1 billion within the next year." Complaint 68. "[W]e continue to expect that our enterprise solutions revenue will achieve $1 billion in 2015." Complaint 80. "[E]nterprise SSD solutions will certainly achieve $1 billion for us in 2015 for our revenue." Complaint 80. "So really all of these on our enterprise business positioning us in a unique and differentiated position leading to $1 billion goal for the year for us in enterprise." Complaint 80 (sic). "[W]e believe, as I said, that we'll be in the upper half of our target financial model in the second half of 2015." Complaint 81. "[O]ur Q4 results and the near-term outlook that we discussed in the call today is really nothing but a temporary setback.... I look forward to a solid progress in our business 4

through the course of the year resulting in substantial momentum in our business in the second half of 2015." Complaint 82. "[W]e believe that we will achieve $1 billion in revenue in our enterprise revenue this year." Complaint 88. "[W]e fully expect that in 2016 time frame, we'll be back to year-over-year growth in our client SSD. Our road map of client SSD solutions is very solid; in fact, we had mentioned in our January call that a 3-bit per cell 1Y client SSDs are in qualifications with OEMs and I would like to point out here that this quarter, we will begin shipments of our X3 1Y client SSDs." Complaint 93. These forward-looking statements were all accompanied by cautionary statements. See Aufhauser Decl., Ex. 1 at 3; Ex. 2 at 3; Ex. 3 at 1; Ex. 4 at 3; Ex. 5 at 3; Ex. 6 at 3; Ex. 7 at 3; Ex. 8 at 3; Ex. 9 at 3; Ex. 10 at 3; Ex. 11 at 1. And contrary to the plaintiffs' argument, these cautionary statements were not too general to be "meaningful" as that term is used in the case law: SanDisk's cautionary language was no more general than language the Ninth Circuit has previously held sufficient. In Intuitive Surgical, it was enough for a company to warn listeners that "comments mentioned on today's call may be deemed to contain forward-looking statements," that "[a]ctual results may differ materially from those expressed or implied, as a result of certain risks and uncertainties," and that "[t]hese risks and uncertainties are described in detail in the company's [SEC] filings." 759 F.3d at 1059 (last alteration in original). SanDisk's cautionary language tracked this format very closely: each cautionary statement warned that SanDisk's representatives would make forward-looking statements, that those forward-looking statements involved certain risks, and that listeners should consult SanDisk's SEC filings to understand those risks more fully. Because the statements listed above are all forward-looking statements accompanied by meaningful cautionary language, the plaintiffs' claims are dismissed to the extent they are based on these statements. The plaintiffs may, of course, use factual allegations regarding these statements to bolster their arguments that other statements are actionable to argue, for example, 5

that other statements were material or made with scienter. But the forward-looking statements are not actionable in their own right. II. Aside from the forward-looking statements, the complaint identifies statements in which SanDisk assessed its progress in integrating Fusion-io, a company it had acquired: "The Fusion-io business performed in line with our expectations post acquisition.... [W]e have made excellent progress in integrating Fusion-io into SanDisk." Complaint 55. "We closed the Fusion-io acquisition in the third quarter and the integration of that business is going extremely well. And so we are very happy with how that's going." Complaint 65. "[We are] very pleased with the rapid progress that SanDisk has made. The SMART Storage acquisition, Fusion-io acquisition, these all are in terms of integration going quite well." Complaint 92. These aren't forward-looking statements: whether the Fusion-io business performed in line with SanDisk's expectations, whether the Fusion-io integration was going well, and whether SanDisk was happy with how the integration was going are all statements that referred to past or present conditions. The plaintiffs may rely on these statements without running afoul of the safe harbor. But, for other reasons, the current complaint does not adequately allege that these statements constitute securities fraud. In particular, the plaintiffs have not adequately pled scienter. To survive this motion to dismiss, the plaintiffs must "state with particularity facts giving rise to a strong inference that the defendant acted with the required state of mind," 15 U.S.C. 78u-4(b)(2)(A) that is, that the defendant engaged in "intentional conduct or deliberate recklessness," Reese v. Malone, 747 F.3d 557, 580 (9th Cir. 2014). "A strong inference of scienter ;must be more than merely plausible or reasonable it must be cogent and at least as compelling as any opposing inference of nonfraudulent intent." Id. at 569 (quoting Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 6

308, 314 (2007)). The current complaint doesn't give rise to an inference of intentional conduct or deliberate recklessness that is "at least as compelling" as any other explanation. Even viewed collectively, Reese, 747 F.3d at 580, the complaint's allegations don't give rise a strong inference that the defendants intentionally (or with deliberate recklessness) made false statements to the investing public about how the integration was going. 1 The complaint's weakness may stem, in part, from the way it's drafted. The complaint is little more than a long list of block quotes from statements made by SanDisk representatives (parts of which have been bolded and italicized for reasons that the complaint does not really explain), followed by further block quotes from analysts (with further unexplained bolding and italicization), connected by a threadbare factual recitation that situates the quoted statements along a basic timeline, but that does little to explain the statements' collective significance in a way that gives rise to any kind of detailed, coherent narrative (as opposed to a skeletal, disjointed chronology) of the defendants' challenged conduct. And because so many of these statements quoted in the complaint are obviously not actionable under the safe harbor, it's hard to tell what if any sense can be made of the remaining handful of statements that might conceivably be actionable. This doesn't meet the demanding pleadings standards of the PSLRA. See Metzler Inv. GMBH v. Corinthian Colls., Inc., 540 F.3d 1049, 1070 (9th Cir. 2008). III. All of the potentially actionable statements identified in the complaint that is, those that don't fall within the PSLRA's safe harbor were made on or after October 16, 2014. That date is significant: it was the date that SanDisk released its third-quarter 2014 earnings, and (relatedly) it was the date that several prospective lead plaintiffs in this litigation used to define the beginning of their proposed class period. The current lead plaintiffs, however, alleged a class period beginning much earlier on April 16, 2014. In appointing the lead plaintiffs, the Court accepted 1 In the same vein, it's not clear that the current complaint adequately alleges falsity or materiality with respect to the statements that don't fall within the safe harbor. But the complaint's failure to plead scienter is so glaring that, for purposes of this motion, it doesn't matter. 7

that earlier date after taking a quick look at the complaint not nearly the hard look it has now taken in response to the motion to dismiss. Cf. Rosian v. Magnum Hunter Res. Corp., No. 13-cv- 2668-KBF, 2013 WL 5526323, at *4 (S.D.N.Y. Oct. 7, 2013) ("The Court has taken only a quick look at the Rule 23 factors" which are among the criteria for appointing a lead plaintiff in a securities case "rather than conducted the in-depth analysis required" for class certification.). After taking a closer look, it appears that the class period proposed by the current lead plaintiffs was artificially long. The PSLRA establishes a rebuttable presumption that the lead plaintiff in a securities case should be whichever entity "has the largest financial interest in the relief sought by the class." 15 U.S.C. 78u-4(a)(3)(B)(iii)(I)(bb). Though this provision was designed to curb gamesmanship among securities plaintiffs, see H.R. Conf. Rep. 104-369 at 32-35 (1995), it has given rise to new forms of gamesmanship. See, e.g., In re Network Assocs., Inc. Secs. Litig., 76 F. Supp. 2d 1017, 1021-27 (N.D. Cal. 1999). In particular, it appears that securities plaintiffs sometimes manipulate their proposed class period in an effort to establish themselves as the presumptive lead plaintiff, where they would not be the largest stakeholder if a shorter, more realistic class period were used. Here, the lead plaintiffs haven't been able to allege even a single statement between April 16, 2014 (the date they picked as the beginning of the class period) and October 16, 2014 (the date picked by other plaintiffs) that falls outside the safe harbor. As weak as the allegations are for the post-october 16 period, they appear frivolous for the pre-october 16 period. "[T]he district court's order designating a lead plaintiff... can be revisited if circumstances warrant." Z-Seven Fund, Inc. v. Motorcar Parts & Accessories, 231 F.3d 1215, 1218 (9th Cir. 2000). Reconsideration may be necessary here. Using a class period that begins on October 16, 2014 (which seems far more realistic), the lead plaintiffs may not have the largest financial interest in the relief sought by the class. Accordingly, the Court invites any interested plaintiff to file a motion asking the Court to reconsider its prior order appointing the current lead plaintiffs. 8

Meanwhile, any amended complaint by the current lead plaintiffs must be filed within 21 days of this order. IT IS SO ORDERED. Dated: January 22, 2016 VINCE CHHABRIA United States District Judge 9