Chung v. Eargo, Inc.

CourtDistrict Court, N.D. California
DecidedFebruary 14, 2023
Docket3:21-cv-08597
StatusUnknown

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

Bluebook
Chung v. Eargo, Inc., (N.D. Cal. 2023).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7

8 Case No. 21-cv-08597-CRB IN RE EARGO, INC. SECURITIES

9 LITIGATION

ORDER GRANTING MOTIONS TO 10 DISMISS 11 This document relates to all consolidated cases. 12

13 14 This consolidated putative securities class action alleges violations of the Securities 15 Act of 1933 (“Securities Act”) and the Securities Exchange Act of 1934 (“Exchange Act”). 16 Lead Plaintiffs IBEW Local 353 Pension Plan and Xiaobin Cai, purchasers of Eargo, Inc.’s 17 publicly traded stock, allege that the company and its executives, directors and IPO 18 underwriters falsely or misleadingly inflated Eargo’s revenue and growth opportunities 19 because the company’s business model was incompatible with the requirements for federal 20 insurance reimbursement. Plaintiffs also claim that Eargo falsely or misleadingly 21 downplayed an insurance audit, which eventually became the subject of a Department of 22 Justice investigation for insurance fraud. 23 Pending before the Court are the Eargo Defendants and the IPO Underwriters’ 24 motions to dismiss the amended consolidated class action complaint for failure to state a 25 claim under Federal Rules of Civil Procedure 12(b)(6) and 9(b). As explained below, the 26 Court grants the motions and dismisses the Complaint in its entirety. 27 I. BACKGROUND 1 A. Factual Background1 2 1. The Parties 3 Defendant Eargo, Inc. was founded in San Jose, California in 2010. Compl. ¶ 2 4 (dkt. 59). It went public in October 2020. Id. ¶ 3. Eargo makes and directly sells air 5 conduction hearing aids to people with mild-to-moderate hearing loss. Id. ¶ 31. Eargo’s 6 president and chief executive officer is Christian Gormsen, and its chief financial officer is 7 Adam Laponis. Id. ¶¶ 27–28. Both corporate officers are named as defendants in this suit, 8 along with members of Eargo’s board of directors, id. ¶ 315, and its IPO underwriters— 9 J.P. Morgan Securities LLC, BofA Securities, Inc., Wells Fargo Securities, LLC, and 10 William Blair & Company, L.L.C., id. ¶ 320. 11 Lead Plaintiffs are IBEW Local 353 Pension Plan, a multi-employer defined benefit 12 pension plan, and Xiaobin Cai, an individual. Id. ¶¶ 24–25. Lead Plaintiffs purchased 13 shares of Eargo common stock and now allege that they purchased the shares at artificially 14 inflated prices and suffered damages because of Defendants’ alleged violations of federal 15 securities laws. Id. They purport to represent investors who purchased or otherwise 16 acquired the common stock of Eargo between November 20, 2020 and March 2, 2022 17 (“Class Period”). 18 2. Eargo’s Business Model 19 Eargo began selling its hearing aids in 2015. Id. ¶ 31. Eargo considers itself as a 20 “disruptor” in the hearing aid industry. Id. ¶ 32. The traditional hearing aid sales model 21 usually requires customers to make in-person visits to hearing aid professionals who 22 examine the customer, perform an audiogram, and prescribe certain hearing aids. Id. The 23 hearing aids are then tested on and fitted to the customer. Id. Eargo found this sales model 24

25 1 These facts are drawn primarily from the Consolidated Complaint. See Dkt. 59. Defendants request that the Court take judicial notice of Eargo’s SEC filings and 26 transcripts from earning calls and investor conferences. Dkt. 77. Judicial notice of these documents, which are heavily referenced in the Complaint, is proper under the incorporate- 27 by-reference doctrine. Khoja v. Orexigen Therapeutics, Inc., 899 F.3d 988, 999 (9th Cir. 1 both archaic and inconvenient for customers because it unnecessarily separates the hearing 2 aid manufacturer from its customers and adds an incremental layer of cost. Id. ¶¶ 32, 34. 3 So Eargo developed a telecare business model that cuts out the middleman. 4 Under its telecare business model, Eargo has an in-house team of hearing aid 5 dispensers who are licensed in one or more states to advise customers on their hearing aid 6 needs. Id. ¶¶ 34, 37. Eargo believes that because it “sells its products online, rather than 7 in physical stores, a dispenser that’s licensed in one state can sell to customers in all of 8 them.” Id. According to Eargo, “potential customers are not required to have a hearing 9 test to order the Eargo hearing solution.” Id. ¶ 36. Eargo tells customers that there is “no 10 need to call an audiologist before calling or buying Eargo. Our team of pros here will 11 work closely with you to understand your hearing situation and determine if Eargo is right 12 for you.” Id. Eargo also provides customers with a “do-it-yourself” hearing test. Id. 13 Under its business model, Eargo touts that a customer could receive its hearing aid “as 14 little as 3 days,” compared to “weeks to months” under the traditional way. Id. ¶ 37. 15 3. Eargo Accepts Insurance by Federal Carriers. 16 Before 2017, Eargo had marketed and sold its products primarily to customers who 17 pay out-of-pocket. Id. ¶¶ 38, 65. Eargo then embarked on a new strategy to target 18 customers with a Federal Employees Health Benefits Program (“FEHBP”) insurance 19 benefit. Id. ¶ 17. 20 FEHBP is the largest employer-sponsored health insurance program in the world. 21 Id. ¶ 4. It provides health benefits through various insurance carriers, such as the Blue 22 Cross Blue Shield Federal Employee Plan (“BCBS FEP”). Id. FEHBP covers over eight 23 million former and current federal employees and their family. Id. Unlike most other 24 medical insurance plans, FEHBP offers hearing aid benefits. Id. BCBS FEP, for example, 25 offers a $2,500 benefit for hearing aids. Id. Eargo priced its hearing aids to commensurate 26 with FEHBP benefits: Eargo’s top-end model costs around $2,500. Id. ¶ 350. 27 To submit a claim for hearing aid reimbursement, FEHBP carriers require that the 1 must be supported by a hearing loss diagnosis, which typically is based on a hearing test 2 performed by a health care provider. See id. ¶¶ 350–51. FEHBP insurance carriers often 3 condition claim reimbursements on a determination of “medical necessity.” Id. ¶ 352. 4 “Over-the-counter” hearing aids generally are “not covered.” See id. ¶ 353. 5 Eargo’s strategy of targeting the FEHBP insurance market initially was a success. 6 It allowed Eargo to expand its customer base beyond cash-pay customers. Id. ¶ 5. Eargo 7 also realized that customers with FEHBP benefits were less likely than cash-pay customers 8 to return the hearing aids because the insurer paid most or all the cost. Id. With these 9 insurance payments, in 2019, Eargo’s net revenue more than doubled: from $32.7 million 10 at year-end 2019 to $69.2 million in 2020. Id. And by the end of 2020, insurance 11 customers comprised approximately 45-percent of Eargo’s total customer base. Id. 12 4. BCBS Audits Eargo. 13 BCBS was Eargo’s largest third-party insurance payor. Id. ¶ 364. On March 15, 14 2021, BCBS mailed a letter to Eargo informing it that BCBS “is required by federal 15 mandates and state statutes to conduct audits and reviews of claims to ensure 16 appropriateness of claims and adequate documentation of clinical services provided to our 17 members. . . . Accordingly, [BCBS is] requesting [Eargo to] provide office/medical 18 records for [28 listed BCBS FEP members] showing all supporting documentation.” Pls.’ 19 Opp., Ex. A at 2 (dkt. 84-2). The letter noted that “[f]ailure to submit the requested 20 information could result in a negative decision being rendered against you regarding these 21 claim payment(s).” Id. 22 A week later, on March 22, Eargo received a faxed letter from BCBS. Id., Ex. B at 23 2 (dkt. 84-3). The March 22 letter included Eargo’s mailing address but appears to be 24 directed at another company. Id. The letter stated: “Dear [unrelated company]: . . .

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Bluebook (online)
Chung v. Eargo, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/chung-v-eargo-inc-cand-2023.