4th Circ. Won't Revive Securities Suit Against Triangle Capital

Law360 (February 22, 2021, 9:34 PM EST) -- The Fourth Circuit said Monday a proposed class suing Triangle Capital Corp. has again failed to show that the business development company intentionally or recklessly misled investors about its mezzanine lending strategy.

In a published opinion, a three-judge appellate panel said the three-year-old litigation still lacked sufficient facts to demonstrate that Triangle knew its lending strategy in 2014 and 2015 was suboptimal and led to poor quality investments but concealed that fact in order to keep its share price inflated.

"The much stronger inference is that defendants had an honest debate about the merits of a subjective business judgment, and in...

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