On April 20, 2018, the Court of Appeals for the Ninth Circuit split from five other circuit courts in Varjabedian v. Emulex Corp., No. 16-55088 (9th Cir. Apr. 20, 2018), by holding that claims under Section 14(e) of the Securities Exchange Act of 1934 require only a showing of negligence rather than intent to defraud.

Read the full memo, Attention Forum Shoppers! Blue Light Special in the Ninth Circuit!