In Re Finjan Holdings, Inc. Securities Litigation

CourtDistrict Court, N.D. California
DecidedApril 13, 2021
Docket3:20-cv-04289
StatusUnknown

This text of In Re Finjan Holdings, Inc. Securities Litigation (In Re Finjan Holdings, Inc. Securities Litigation) 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
In Re Finjan Holdings, Inc. Securities Litigation, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 IN RE FINJAN HOLDINGS, INC. Case No. 20-cv-04289-EMC SECURITIES LITIGATION. 8 ORDER GRANTING DEFENDANTS’ 9 MOTION TO DISMISS 10 Docket No. 24 11

12 13 14 Lead Plaintiff Robert Grier has filed a securities action against Finjan Holdings, Inc. 15 (“Finjan”), its President and CEO Philip Hartstein, and former members of Finjan’s Board of 16 Directors (eight individuals1). Lead Plaintiff asserts that Defendants violated §§ 14(e) and 20(a) 17 of the Securities Exchange Act of 1934 based on misrepresentations related to a tender offer in 18 which Fortress Investment Group LLC, through an affiliate, acquired all of Finjan’s stock for 19 $1.55 per share. The misrepresentations, which effectively undervalued Finjan’s shares, were 20 contained in the Recommendation Statement (Schedule 14D-9) and/or amendments thereto that 21 Defendants disseminated to Finjan shareholders. See generally Defs.’ RJN, Ex. A (Rec. St. at 12) 22 (stating that, the Board unanimously “determined that the Offer, the Merger and the other 23 transactions contemplated by the Merger Agreement are fair to and in the best interests of the 24 Company and its stockholders” and “recommended that the stockholders of the Company tender 25 their Shares in the Offer”). Currently pending before the Court is Defendants’ motion to dismiss. 26 27 1 Having considered the parties’ briefs and accompanying submissions, the Court hereby 2 GRANTS the motion to dismiss but gives Lead Plaintiff leave to amend. 3 I. FACTUAL & PROCEDURAL BACKGROUND 4 A. Finjan 5 As alleged in the operative complaint, Finjan is a cybersecurity business. It has three 6 wholly-owned subsidiaries (sometimes referred to as “lines of business” by Lead Plaintiff): 7 • Finjan Mobile, Inc. (“FMI”); 8 • Finjan, Inc. (“FI”); and 9 • Finjan Blue, Inc. (“FBI”). 10 FMI operates a mobile security business. FI and FBI focus on investing in cybersecurity 11 technologies and intellectual property, intellectual property licensing, and intellectual property 12 enforcement. See FAC ¶ 27. According to Lead Plaintiff, Finjan derives most of its revenue from 13 intellectual property licensing and intellectual property enforcement. See FAC ¶ 28.2 14 B. General Timeline re Merger 15 Based on the Recommendation Statement,3 it appears that the Finjan Board first considered 16 strategic options, including but not limited to a sale of the company, back in the spring of 2018. 17

18 2 Lead Plaintiff alleges that, as part of its intellectual property, Finjan has a portfolio of patents that “relate[s] to software and hardware technologies that detect malicious code and thereby 19 protect end users from identity and data theft, spyware, malware, phishing, trojans, and other web and network threats.” FAC ¶ 28; see also FAC ¶ 30 (alleging that, as of May 2020, “Finjan had 20 more than 50 organically-developed patents issued worldwide,” as well as “90+ complementary patents [acquired from, e.g.,] IBM”). 21

3 The Court may consider the Recommendation Statement even at the 12(b)(6) phase because of 22 the incorporation-by-reference doctrine. See Khoja v. Orexigen Therapeutics, Inc., 899 F.3d 988, 1002 (9th Cir. 2018) (noting that (1) “incorporation-by-reference is a judicially created doctrine 23 that treats certain documents as though they are part of the complaint itself”; that (2) “[t]he doctrine prevents plaintiffs from selecting only portions of documents that support their claims, 24 while omitting portions of those very documents that weaken – or doom – their claims”; and that (3) “a defendant may seek to incorporate a document into the complaint ‘if the plaintiff refers 25 extensively to the document or the document forms the basis of the plaintiff's claim’”).

26 That being said, the Court bears in mind that “what inferences a court may draw from an incorporated document should . . . be approached with caution. . . . [U]nlike judicial notice, a court 27 ‘may assume [an incorporated document's] contents are true for purposes of a motion to dismiss 1 See Rec. St. at 13. “[T]he Board authorized the formation of a transaction committee . . . , 2 consisting of independent directors Eric Benhamou and Michael Southworth,” which, “in 3 coordination with the Company's Chairman, Daniel Chinn, was delegated the power to oversee a 4 sales process and make certain day-to-day decisions [although] not empowered to ultimately reject 5 or approve any transaction.” Rec. St. at 13. The Board also hired a financial advisor, Atlas. See 6 Rec. St. at 14. There is no allegation that Atlas was biased or was acting in self-interest in doing 7 its work for the Board. 8 Atlas began an outreach to potential transaction partners. It contacted more than 50 9 companies, of which 11 eventually entered into confidentiality agreements with Finjan. See Rec. 10 St. at 14. Among these companies were Fortress and a company identified in the 11 Recommendation Statement as “Party B.” See Rec. St. at 14-20. Finjan had discussions with the 12 companies, including Fortress and Party B, but nothing came to fruition by December 2019 (i.e., 13 after almost 2 years of effort). Thereafter, in February 2020, the Finjan Board decided to close the 14 process and to focus instead on moving forward as an independent company. See Rec. St. at 21. 15 By April 2020, however, the Board appeared to change course and discussions began anew 16 with both Party B and Fortress. On April 1, 2020, Party B expressed an interest in acquiring 17 Finjan for $1.50 per share. See Rec. St. at 21. By late April, however, Party B indicated that “it 18 was not willing to pursue a transaction at $1.50 per share and proposed restructuring the 19 transaction as an asset purchase. Party B also indicated that it would need to perform further due 20 diligence on the Company.” Rec. St. at 22. 21 Subsequently, on May 5, 2020, Fortress proposed to acquire Finjan for $1.50 per share. 22 Three days later, Fortress raised the proposal to $1.55 per share. See Rec. St. at 23. The Merger 23 Agreement between Finjan and Fortress – which provided for a merger consideration of $1.55 per 24 share – was ultimately entered into and announced on or about June 10, 2020. The $1.55 merger 25 consideration represented a premium of approximately 15.8% to the company’s closing share 26 price on June 8, 2020, and a premium of approximately 20.2% to the company’s closing share 27 price on June 1, 2020 (i.e., one week earlier). See Rec. St. at 25. 1 that shareholders tender their shares. The Recommendation Statement was subsequently amended 2 and supplemented on July 8, 16, and 23, 2020. 3 The merger was ultimately completed on or about July 24, 2020. 4 C. Recommendation Statement 5 The Recommendation Statement issued by the Finjan Board was supported by a Fairness 6 Opinion. Atlas, as the financial advisor, was hired to prepare the Fairness Opinion. See Rec. St. 7 at 30. For the Fairness Opinion, Atlas did (1) a Premiums Paid Analysis, (2) a Selected Public 8 Company Trading Multiples Analysis, and (3) a Discounted Cash Flow Analysis. 9 • Under the Premiums Paid Analysis, Atlas found that the value of Finjan stock was 10 about $1.56 to $1.64 per share. See Rec. St. at 31. 11 • Under the Selected Public Company Trading Multiples Analysis, Atlas found that 12 the value of Finjan stock was about $1.62 to $1.63 per share. See Rec. St. at 34. 13 • Under the Discounted Cash Flow Analysis, Atlas found that the value of Finjan 14 stock was about $1.42 to $1.55. See Rec. St. at 33. 15 As indicated above, under the terms of the tender offer, Finjan shareholders would get 16 $1.55 per share.

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Bluebook (online)
In Re Finjan Holdings, Inc. Securities Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-finjan-holdings-inc-securities-litigation-cand-2021.