Bushansky v. Kawas

CourtDistrict Court, W.D. Washington
DecidedMay 3, 2024
Docket2:22-cv-00497
StatusUnknown

This text of Bushansky v. Kawas (Bushansky v. Kawas) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bushansky v. Kawas, (W.D. Wash. 2024).

Opinion

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3 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 4 AT SEATTLE 5 STEPHEN BUSHANSKY, derivatively on behalf of ATHIRA PHARMA, INC., 6 Plaintiff, 7 v. 8 LEEN KAWAS; KELLY A. ROMANO; C22-0497 TSZ JOSEPH EDELMAN; JOHN M. FLUKE, [consolidated with C22-0620 TSZ] 9 JR.; JAMES A JOHNSON; BARBARA KOSACZ; and MARK LITTON, ORDER 10 Defendants, and 11 ATHIRA PHARMA, INC., 12 Nominal Defendant. 13 THOMAS HOULIHAN, derivatively on behalf of ATHIRA PHARMA, INC., 14 Plaintiff, 15 v. LEEN H. KAWAS; KELLY A. ROMANO; 16 JOSEPH EDELMAN; JOHN M. FLUKE, JR.; JAMES A. JOHNSON; BARBARA 17 KOSACZ; MARK LITTON; and KEVIN CHURCH, 18 Defendants, 19 and ATHIRA PHARMA, INC., 20 Nominal Defendant. 21 THIS MATTER comes before the Court on an unopposed motion, docket no. 17, 22 1 of Civil Procedure 23.1(c), for preliminary approval of a proposed settlement of this 2 shareholder derivative action, as well as the litigation demands of Ali Soofi and Travis

3 Vrana, who own stock in Athira Pharma, Inc. (“Athira”). Having reviewed all papers 4 filed in support of the motion, the Court enters the following Order. 5 Discussion 6 A. Applicable Standards 7 A shareholder derivative action may be settled or compromised only with the 8 Court’s approval. Fed. R. Civ. P. 23.1(c). Within the Ninth Circuit, the “proper legal

9 standard” to apply under Rule 23.1(c) is whether the settlement is fair, reasonable, and 10 adequate to the nominal defendant, i.e., the entity in which the derivative plaintiffs are 11 shareholders. See In re Pac. Enters. Sec. Litig., 47 F.3d 373, 377–78 (9th Cir. 1995); see 12 also Bell Atl. Corp. v. Bolger, 2 F.3d 1304, 1311 (3d Cir. 1993); Zimmerman v. Bell, 800 13 F.2d 386, 391 (4th Cir. 1986); Republic Nat’l Life Ins. Co. v. Beasley, 73 F.R.D. 658, 667

14 (S.N.D.Y. 1977) (“The role of the Court in passing upon the propriety of a settlement in a 15 derivative action is to determine whether the proponents of the settlement have shown 16 that it fairly and adequately serves the interests of the corporation on whose behalf the 17 derivative action was instituted.”). 18 Analyzing whether a proposed settlement is fair, reasonable, and adequate requires

19 consideration of (i) whether the proposed settlement was fairly and honestly negotiated, 20 (ii) whether serious questions of law and/or fact exist, reducing the chances of a favorable 21 outcome, and (iii) whether the value of an immediate recovery outweighs the probable 22 future relief after further litigation, which might be protracted and expensive. See Jones 1 v. Nuclear Pharm., Inc., 741 F.2d 322, 324 (10th Cir. 1984); Bell Atl., 2 F.3d at 1311–15 2 (reviewing the substantive and procedural fairness of the settlement at issue); see also In

3 re Pac. Enters., 47 F.3d at 378. The opinions of the mediator, any independent counsel, 4 the attorneys involved in the case, and/or the parties concerning the fairness and 5 reasonableness of the proposed settlement are also factors in the assessment under 6 Rule 23.1(c). See Jones, 741 F.2d at 324; see also In re Pac. Enters., 47 F.3d at 378. 7 The Court must also exercise its discretion in determining what manner of notice 8 about the proposed settlement should be provided to shareholders. See Fed. R. Civ.

9 P. 23.1(c). The notice must be sufficiently informative and offer an adequate opportunity 10 to respond. Bell Atl., 2 F.3d at 1317; Maher v. Zapata Corp., 714 F.2d 436, 451–52 11 (5th Cir. 1983) (concluding that the distributed notice “adequately described the nature 12 of the pending action, the claims asserted therein, and the general terms of the proposed 13 settlement,” informed the shareholders of how they could learn more about the case, the

14 time and place for the final approval hearing, and their right to participate in such 15 hearing, and was “worded as to make reasonably clear to the ‘minimally sophisticated 16 layman’” the primary consequences of the settlement). The notice must be provided in a 17 way that is likely “to reach the majority of interested shareholders.” In re Wells Fargo & 18 Co. Shareholder Derivative Litig., 445 F. Supp. 3d 508, 517 (N.D. Cal. 2020).

19 B. Proposed Settlement 20 In April and May 2022, Bushansky and Houlihan, respectively, filed verified 21 stockholder derivative complaints alleging that certain members of Athira’s Board of 22 Directors (“Board”) and/or current and former officers of the corporation breached their 1 fiduciary duties and engaged in other improper conduct that materially damaged Athira 2 and its shareholders. See Compl. (C22-497, docket no. 1); Compl. (C22-620, docket

3 no. 1). These claims are premised on the same nucleus of facts described in the Court’s 4 rulings in a related class action, in which a proposed settlement is also pending the 5 Court’s approval. See Nacif v. Athira Pharma, Inc., No. C21-861, 2022 WL 3028579 6 (W.D. Wash. July 29, 2022) (granting in part and denying in part defendants’ motion to 7 dismiss); see also Nacif v. Athira Pharma, Inc., No. C21-861, 2024 WL 643513 (W.D. 8 Wash. Feb. 15, 2024) (preliminarily approving a proposed class settlement).

9 In November 2022 and September 2023, Soofi and Vrana, respectively, served 10 stockholder litigation demands on Athira’s Board. See Stip. of Settlement & Release 11 Agr. at 3 & ¶ V(A)(17) (docket no. 18-1). Bushansky, Houlihan, Soofi, and Vrana 12 (collectively, “Plaintiffs”) now propose to release their claims in exchange for certain 13 corporate governance reforms to be implemented and maintained for at least five years.

14 See id. at ¶ V(B)(1) & Ex. 1–4. Plaintiffs have summarized these reforms as follows: 15 • Create a new senior management officer—the Chief Compliance Officer—to manage and oversee the Company’s ethics and compliance 16 program, implement procedures for monitoring and evaluating the program’s performance, and communicate with and inform the newly- 17 created Compliance Committee and the Audit Committee regarding progress towards meeting program goals. 18 • Create a Compliance Committee of the Board of Directors, consisting of 19 at least two independent directors, to oversee compliance with healthcare, legal and regulatory requirements; the safety and effectiveness of the 20 Company’s products and product candidates in clinical and pre-clinical development; the integrity of scientific research and accuracy and 21 completeness of the Company’s scientific publications; the qualification and performance of candidates in clinical and preclinical development; 22 and the qualification and performance of contract research and contract manufacturing organizations.

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