Securities Fraud — Dismissal

Yesterday, the Eastern District of Michigan dismissed with prejudice the securities fraud class action captioned In re United American Healthcare Corp. Secs. Litig., 2007 U.S. Dist. LEXIS 6362 (Jan. 30, 2007). First, it reasoned that there was no duty to disclose the undisclosed information. Second, it held that, even if the group pleading doctrine survived enactment of the PSLRA, scienter had to be, and was not, alleged with specificity as to each defendant. Third, it dismissed GAAP allegations on 9(b) grounds. Fourth, it dismissed § 20(a) claims due to the absence of a viable underlying 10b-5 violation.

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