Gas Leak

The Ninth Circuit upheld the dismissal of a putative shareholder class action against Sempra Energy and Southern California Gas Company alleging defendants’ misstatements before and after a “massive” natural gas leak from the Aliso Canyon gas storage reservoir triggered a drop in Sempra’s share price. The plaintiffs failed to “identify any particular defendant who made a false or misleading statement.”

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Bank of Internet

The Ninth Circuit revived a securities fraud class action brought by shareholders who claim BofI Holdings falsely portrayed the bank holding company — which operated the “Bank of Internet” — as being a safer investment than it was. The company’s stock price fell by more than 30% after the market learned of a whistleblower’s allegations, which the shareholders can rely on as a corrective disclosure to prove loss causation.

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