Cai v. Eargo, Inc.

CourtCourt of Appeals for the Ninth Circuit
DecidedJanuary 10, 2025
Docket23-3470
StatusUnpublished

This text of Cai v. Eargo, Inc. (Cai v. Eargo, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cai v. Eargo, Inc., (9th Cir. 2025).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JAN 10 2025 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

XIAOBIN CAI; IBEW LOCAL 353 No. 23-3470 PENSION PLAN, D.C. No. 3:21-cv-08597-CRB Plaintiffs - Appellants,

v. MEMORANDUM*

EARGO, INC.; CHRISTIAN GORMSEN; ADAM LAPONIS; JOSH MAKOWER; JULIET BAKKER; PETER TUXEN BISGAARD; DOUG HUGHES; GEOFF PARDO; A. BROOKE SEAWELL; DAVID WU; NINA RICHARDSON; J.P. MORGAN SECURITIES LLC; BOFA SECURITIES, INC.; WELLS FARGO SECURITIES, LLC; WILLIAM BLAIR & COMPANY, L.L.C.,

Defendants - Appellees.

Appeal from the United States District Court for the Northern District of California Charles R. Breyer, District Judge, Presiding

Argued and Submitted December 5, 2024 San Francisco, California

Before: M. SMITH and BUMATAY, Circuit Judges, and WU, Senior District

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. Judge.**

Xiaobin Cai and IBEW Local 353 Pension Plan sued Eargo, Inc. and the other

defendants for securities violations under the Securities Act of 1933 (“Securities

Act”) and the Securities and Exchange Act of 1934 (“Exchange Act”). The district

court dismissed Plaintiffs’ complaint for failure to state a claim under Federal Rule

of Civil Procedure 12(b)(6). Plaintiffs declined leave to amend and now appeal the

district court’s dismissal. We have jurisdiction under 28 U.S.C. § 1291, review de

novo, and affirm. See Prodanova v. H.C. Wainwright & Co., LLC, 993 F.3d 1097,

1105 (9th Cir. 2021).

1. We begin with the Securities Act. Issuers face liability for filing a

prospectus ahead of an initial public offering (“IPO”) that contains materially false

statements or omits information needed to ensure a statement is not misleading. See

15 U.S.C. § 77k(a). Plaintiffs must “demonstrate (1) that the registration statement

contained an omission or misrepresentation, and (2) that the omission or

misrepresentation was material, that is, it would have misled a reasonable investor

about the nature of his or her investment” to survive dismissal. Anderson v. Clow

(In re Stac Elecs. Sec. Litig.), 89 F.3d 1399, 1403–04 (9th Cir. 1996) (simplified).

No showing of scienter is required. Id.

** The Honorable George H. Wu, United States Senior District Judge for the Central District of California, sitting by designation.

2 23-3470 Plaintiffs’ Securities Act claims focus on three areas: (1) statements about

Eargo’s revenue recognition; (2) statements about potential risk factors; and (3)

statements about Eargo’s potential growth. For example, Plaintiffs contend that

Eargo’s statements that “the Company assesses insurance eligibility,” was

misleading because Eargo did not confirm with its insurers that its online screening

test or a customer self-assessment was sufficient to satisfy insurers’ medical

necessity requirements. Plaintiffs also claim that Eargo should not have recognized

insurance revenue because the insurance claims ultimately proved to be non-

reimbursable. And Plaintiffs contend that Eargo failed to satisfy its 17 C.F.R. §

229.303(b)(2)(ii) (“Item 303”) requirement because it did not disclose “the known

uncertainties and risks of having to forfeit past insurance proceeds” or risks

associated with insurers’ exclusion of “over-the-counter” hearing aids from

coverage.

We affirm the dismissal of these claims. In context, the prospectus made clear

that Eargo was evaluating whether a potential customer had an insurance policy that

covered hearing aids. Further, insurers had reimbursed Eargo’s claims for nearly

three years before the statements in the prospectus were made. And “[f]raud by

hindsight is not actionable.” Ronconi v. Larkin, 253 F.3d 423, 430 n.12 (9th Cir.

2001) (simplified), abrogated on other grounds by Matrixx Initiatives v. Siracusano,

563 U.S. 27, 37–49 (2011). Instead, Eargo’s prospectus disclosed a wide range of

3 23-3470 potential risks to its business, including the inherent risk of a new market-disrupting

business model, the possibility that insurers could limit or reduce coverage, and the

legal risks of failing to comply with federal laws and regulations such as the False

Claims Act. These disclosures put prospective investors on notice of the

fundamental risks to Eargo’s business. And Eargo’s growth statements are clearly

puffery and thus non-actionable. See Police Ret. Sys. of St. Louis v. Intuitive

Surgical, Inc., 759 F.3d 1051, 1060 (9th Cir. 2014) (“Statements of mere corporate

puffery . . . are not actionable[.]”).

2. We also affirm the dismissal of Plaintiffs’ Exchange Act claims. See 17

C.F.R. § 240.10b-5(b); 15 U.S.C. § 78j(b). While Exchange claims contain six

elements, only whether Eargo made a “material misrepresentation or omission” and

had “scienter” are contested. See Levi v. Atossa Genetics, Inc. (In re Atossa Genetics

Inc. Sec. Litig.), 868 F.3d 784, 793 (9th Cir. 2017) (simplified). Plaintiffs’

misrepresentation claims focus on four categories of post-IPO statements: (1)

statements about Blue Cross Blue Shield (“BCBS”)’s audit; (2) statements about

revenue recognition; (3) statements about risk factors; and (4) statements about

Eargo’s growth.

These statements include Eargo’s description of BCBS’s audit as “routine,”

that the audit was part of “an educational process” with BCBS, and that BCBS was

“not questioning claims.” Plaintiffs again challenge Eargo’s statements that it

4 23-3470 “validates,” “verif[ies],” or “assesses” its customers’ insurance eligibility. Plaintiffs

also argue Eargo’s risk factor statements were misleading because they presented

the risks as hypothetical when they “had already materialized.” Plaintiffs further

claim that Eargo’s post-IPO growth statements were false or misleading. Plaintiffs

have not shown that these statements were misleading.

In context, Eargo explained that much of its business growth depended on

insurance reimbursement, that its business could suffer significantly if it had issues

with insurers, and that it could face serious liability if it was found to violate the

False Claims Act. Eargo disclosed the BCBS audit and the potential damage that it

may cause. It explained that BCBS accounted for much of its income, that the audit

could result “in significant delays in payment,” and that BCBS was already

withholding payments. Further, Eargo’s description of the audit as “routine” was an

opinion, and Plaintiffs do not allege with particularity that this was an actionable

statement. See City of Dearborn Heights Act 345 Police & Fire Retirement Sys. v.

Align Tech., Inc., 856 F.3d 605, 614–16 (9th Cir. 2017); Fed.

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