In Re Finjan Holdings, Inc. Securities Litigation

District Court, N.D. California·Decided September 13, 2021·No. 3:20-cv-04289·Unknown

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 SECOND AMENDED COMPLAINT 10 Docket No. 46 11

12 13 14 The above-referenced case is a securities action filed against Finjan Holdings, Inc. 15 (“Finjan”) and its President and CEO Philip Hartstein.1 Lead Plaintiff (an individual, Robert 16 Grier) asserts that Defendants violated §§ 14(e) and 20(a) of the Securities Exchange Act of 1934 17 based on misrepresentations related to a tender offer in which Fortress Investment Group LLC, 18 through an affiliate, acquired all of Finjan’s stock for $1.55 per share. The alleged 19 misrepresentations were contained in the Recommendation Statement (Schedule 14D-9) and/or 20 amendments thereto that Defendants disseminated to Finjan shareholders prior to their making a 21 decision on whether to tender their shares in the offer. See generally Defs.’ RJN, Ex. A (Rec. St. 22 at 12) (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”). 26 Previously, the Court dismissed Lead Plaintiff’s first amended complaint (“FAC”) based 27 1 on failure to plead subjective falsity. Lead Plaintiff, however, was given leave to amend, and thus 2 he filed the operative second amended complaint (“SAC”). Now pending before the Court is 3 Defendants’ motion to dismiss the SAC. 4 FACTUAL & PROCEDURAL BACKGROUND 5 The gist of Lead Plaintiff’s suit is that Defendants made material misrepresentations about 6 the value of the company (i.e., undervaluing it). Specifically, in the Recommendation Statement 7 issued in June 2020, Defendants claimed that Fortress’s offer of $1.55 per share was reasonable 8 based on financial projections that Finjan would have revenues of about $166 million for the 9 period 2020-2024.2 However, just six months earlier, in December 2019, Defendants claimed that 10 Finjan expected to generate approximately $200-400 million in revenue for the period 2019-2022 11 – and this was with respect to just one line of business (licensing and enforcement) out of three. 12 Lead Plaintiff contends that nothing happened in the six-month period that would have warranted 13 such a drastic reduction in the value of the company. In fact, Lead Plaintiff asserts, Finjan 14 management made optimistic statements during the six-month period and further indicated that 15 COVID-19 would not be an issue (e.g., even if trials would be delayed, they would still take place 16 before 2024 and thus projected revenue might be delayed but not altogether eliminated). Lead 17 Plaintiff also maintains that third parties also viewed Finjan favorably during this six-month 18 period. See, e.g., SAC ¶ 67 (alleging that “Dmitriy Kozin, a sophisticated Finjan investor who 19 closely followed the Company, explained in an article entitled ‘COVID-19 or not, Finjan should 20 do well,’ the Company was ‘realistically worth 3x more than [its then] current share price and 21 potentially 10x more’”); SAC ¶ 129 (alleging that, in an article dated May 18, 2020, “Investor 22 Observer, a financial investment website, noted that “‘the average rating from Wall Street 23 analysts, FNJN stock has a mean target price of $5,’” which “‘means analysts expect the stock to 24 rise 252.11% over the next 12 months’”). 25 A. Prior 12(b)(6) Proceedings 26 During the prior 12(b)(6) proceedings, the Court noted that Lead Plaintiff had to make a 27 1 plausible showing of both objective and subjective falsity in order to have a viable claim. The 2 Court did not make a definitive ruling on objective falsity. See Docket No. 18 (Order at 18-19) 3 (acknowledging allegations made by Lead Plaintiff but also noting that there were facts that 4 indicated the tender offer was fair – e.g., (1) “in the months preceding the tender offer, the stock 5 had not always performed well and/or revenues were low”; (2) “[t]he merger consideration of 6 $1.55 per share was more than the then-current stock price”; (3) “Party B had made an offer 7 ($1.50 per share) that was similar in value to the merger consideration, and there were no other 8 suitors”; (4) “[u]nder the Premiums Paid Analysis (also part of the Fairness Opinion), Atlas found 9 that the value of Finjan stock could be as low as $1.56 per share”; and (5) there was “uncertainty 10 in the future, both because of COVID-19 and the nature of Finjan’s business (patent licensing and 11 enforcement which involves extended negotiations and at times litigation”; but ultimately not 12 resolving the issue of objective falsity). 13 However, the Court held that Lead Plaintiff failed to allege a viable claim because 14 subjectively falsity was insufficiently pled. Subjective falsity meant that Lead Plaintiff had to 15 plead “facts giving rise to a strong inference that Defendants did not believe [the financial 16 projections of $166 million for the 2020-2024 period] were true – i.e., that Defendants knew that 17 the [financial projections] were false even though they were presenting them to Atlas as true for 18 purposes of developing the Fairness Opinion.” Docket No. 41 (Order at 20) (emphasis in 19 original). The Court noted that, “[i]n a recent opinion, the Ninth Circuit underscored that, if a 20 ‘complaint fails to plead a plausible motive for the allegedly fraudulent action, the plaintiff will 21 face a substantial hurdle in establishing scienter.’” Docket No. 41 (Order at 20). Here, Lead 22 Plaintiff’s FAC did not explain why Defendants would endorse the financial projections as true if 23 they actually believed them to be false.

24 The FAC does not contain any allegations suggesting that Defendants would secure unique benefits not afforded to 25 shareholders if the tender offer were to go through. Nor are there any other allegations suggesting that Defendants’ interests regarding 26 the tender offer were not aligned with those of the shareholders. In fact, two Defendants were independent directors (notably, the two 27 who made up the Transaction Committee), and thus would appear to of Prodanova [the recent Ninth Circuit case]. 1 Moreover, the failure to allege a plausible motive cannot be 2 overlooked here because there are not compelling and particularized facts alleged in support of the claim of fraudulent intent. As noted 3 above, the independent board members on the Transaction Committee supported the tender offer. Furthermore, there was 4 concrete market evidence that the merger consideration of $1.55 per share was reasonable – i.e., at or about the same time of Fortress’s 5 offer, Party B had made an offer of $1.50 per share. So did Fortress. There were no other interested parties despite Atlas’s marketing 6 efforts. This evidence of what the actual market was willing to offer is direct evidence of market value unlike the circumstantial and 7 interpretive approach of, e.g., Atlas’s Premiums Paid Analysis and Selected Public Company Trading Multiples Analysis (which, 8 unlike the Discounted Cash Flow Analysis, were not derived from the [allegedly false financial projections]). 9 10 Docket No. 41 (Order at 21). 11 Because subjective falsity was not adequately pled, the Court dismissed the securities 12 claims brought by Lead Plaintiff but gave him leave to amend. 13 B. Allegations in the SAC 14 In the operative SAC, Lead Plaintiff repeats many of the same allegations as contained in 15 the prior FAC. He has, however, added some new allegations. The main allegations that have 16 been added to the SAC are (1) a more detailed recounting of the sales process that took place 17 before Fortress made its offer of $1.55 per share and (2) an explanation of why Mr.

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

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