'Plausible' Inference Of Fraud Fails Tellabs Test

Law360 (June 10, 2008, 12:00 AM EDT) -- In a recent securities fraud class action decision, Skubella v. CheckFree Corp., Civil Action No. 1:07-CV-796-TWT, 2008 WL 1902118 (N.D. Ga. Apr. 25, 2008), the U.S. District Court for the Northern District of Georgia granted the defendants’ motion to dismiss for failure to state a claim under the pleading requirements of the Private Securities Litigation Reform Act (the “Reform Act”).

The plaintiff had alleged that defendants engaged in accounting fraud in order to mask the fact that the company’s sales volume was declining. Id. at *1....
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