IN RE NATIONAL INSTRUMENTS CORPORATION SECURITIES LITIGATION

CourtDistrict Court, S.D. New York
DecidedSeptember 6, 2024
Docket1:23-cv-10488
StatusUnknown

This text of IN RE NATIONAL INSTRUMENTS CORPORATION SECURITIES LITIGATION (IN RE NATIONAL INSTRUMENTS CORPORATION SECURITIES LITIGATION) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
IN RE NATIONAL INSTRUMENTS CORPORATION SECURITIES LITIGATION, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------- X : IN RE NATIONAL INSTRUMENTS CORPORATION : SECURITIES LITIGATION : 23-cv-10488 : (DLC) : : OPINION AND --------------------------------------- X ORDER

APPEARANCES:

For Lead Plaintiff: Chad Johnson Noam Mandel Desiree Cummings Jonathan Zweig Christopher Gilroy Robbins Geller Rudman & Dowd LLP 420 Lexington Avenue, Suite 1832 New York, NY 10170

For defendants: James F. Bennett J. Russel Jackson Dowd Bennett LLP 7676 Forsyth Blvd, Ste. 1900 St. Louis, MO 63105

Andrew Ditchfield Davis Polk & Wardwell LP 450 Lexington Avenue New York, NY 10017

DENISE COTE, District Judge: National Instruments Corporation (“NI” or the “Corporation”) has been sued by shareholders who sold their stock in 2022. Lead plaintiff alleges that NI and three of its senior executives violated the securities laws by failing to disclose that NI had received an offer to purchase the company. After receiving the offer, NI continued to engage in a stock buyback program that it had begun earlier that year. Because of the omission of the offer, shareholders assert that they sold their common stock at artificially depressed prices, including selling stock back to NI. The defendants have moved to dismiss the complaint. For

the following reasons, the defendants’ motion to dismiss is granted in part. Background The following facts are taken from the complaint and documents incorporated therein. For the purposes of deciding this motion, the complaint’s factual allegations are accepted as true, and all reasonable inferences are drawn in the plaintiff’s

favor. NI produced automated test equipment and virtual instrumentation software. Defendant Eric Starkloff was the Chief Executive Officer and President of NI and a member of NI’s Board of Directors (the “Board”). Defendant Michael McGrath was the Chairman of the Board. Defendant Karen Rapp was an Executive Vice President and the Chief Financial Officer of NI. Rapp stepped down as CFO on January 9, 2023, and assumed an advisory role with NI until her retirement in May of 2023. On January 19, 2022, NI’s Board approved a stock repurchase program authorizing NI to repurchase up to $250 million worth of common stock from shareholders, effective immediately (the “2022 Stock Repurchase Plan”). This plan represented the largest stock buyback in the company’s history. NI had previously authorized a stock repurchase plan in 2010, which was amended in

2019 to increase the number of shares that may be repurchased (the “2019 Stock Repurchase Plan”). NI repurchased stock throughout 2022. In January and February, NI repurchased 270,445 shares under the 2019 Stock Repurchase Plan at an average price of $41.10. These repurchases accounted for all of the remaining shares available for repurchase under the 2019 Stock Repurchase Plan. Also in February, NI purchased 337,541 shares under the 2022 Stock Repurchase Plan at an average price of $41.14. In March, NI purchased 164,066 shares at an average price of $39.34. NI repurchased 702,506 shares in April at an average price of

$40.63; 284,370 shares in May at an average price of $35.17; 520,902 shares in August at an average price of $41.91; and 1,512,233 shares in September at an average price of $39.68. NI did not repurchase any shares in June, July, October, November, or December. Altogether, NI repurchased 3,792,063 shares in 2022, 3,521,618 of which were repurchased under the 2022 Stock Repurchase Plan. NI disclosed the repurchases in its quarterly filings with the SEC on Forms 10-Q and in its quarterly investor conference calls. On October 11, 2023, Emerson Electric Co. (“Emerson”), a company that manufactures and provides engineering services for industrial, commercial, and consumer markets, acquired NI.

Emerson began making overtures to purchase NI in May of 2022. On May 25, Emerson’s CEO emailed a letter to Starkloff that detailed Emerson’s initial offer to acquire 100% of the outstanding common stock of NI for $48 in cash per common share (the “May 25 Letter”). NI’s stock closed that day at $34.35 per share. The May 25 Letter stated that Emerson was “very excited” about the possibility of a merger, was “prepared to move very quickly” toward a definitive merger statement, and preferred to negotiate in private. On June 14, NI’s Board rejected Emerson’s offer. The Board concluded that Emerson’s proposal “substantially undervalued” NI. On June 16, Starkloff and

McGrath notified Emerson of the rejection. On June 22, Emerson renewed its offer at $48 per share, but represented that “with access to limited non-public information after signing an NDA, we could work with you to find additional value” (the “June 22 Letter”). Emerson expressed that it was “very motivated to conclude a transaction” and that acquiring NI was Emerson’s “highest strategic priority.” At the Board meeting on July 19 and 20, NI’s Board and management again rejected the offer as “inadequate.” The Board discussed with management and advisors the potential for Emerson to change its offer and steps that NI could take to highlight its momentum and financial performance. At the same time, the Board instructed

management not to provide diligence materials to Emerson. On August 2, Starkloff and McGrath advised Emerson that “the Board remains unanimously of the view that your proposal is not in the best interests of NI and its shareholders.” On July 28, NI issued a press release, filed on Form 8-K, announcing its second quarter 2022 financial results. The release announced substantially improved financial guidance over the projections from the first quarter of 2022. The release quoted Starkloff as stating that the second quarter’s results brought “increased confidence in achieving revenue growth and earnings per share in line with current consensus estimates.”

On November 3, having had no contact with NI since August 2, Emerson made an offer to purchase NI at $53 per share and reiterated its desire to move quickly to complete the transaction (the “November 3 Letter”). The November 3 Letter warned that Emerson was willing to bring its offer directly to shareholders if NI continued in its refusal to engage. In response, NI established a working group of the Board to examine the proposal. On January 13, 2023, prior to the opening of trading, NI issued a press release announcing that its Board had initiated a review and evaluation of strategic options, including solicitation of interest from potential acquirors and other

transaction partners, “some of whom have already approached the Company.” The press release stated that there was “no deadline or definitive timetable set for completion of the strategic review” and “no assurance” that the process would “result in any specific transaction.” It also announced the implementation of a “limited duration shareholder rights plan” that was intended to “reduce the likelihood that any person or group gains control of the Company through open market accumulation or other tactics and reduce the likelihood that actions are taken by third parties that are not in the best interest of the Company and all of its shareholders.” NI’s statement did not mention Emerson or

any of Emerson’s offers to acquire NI. NI’s stock price surged from the previous day’s close of $40.17 per share to a high of $47.95 per share and closed at $46.50 per share on January 13, on unusually high trading volume of over 7.7 million shares. On January 17, prior to the opening of trading, Emerson issued a press release announcing that it had made an all-cash offer to purchase all of the shares of NI for $53 per share. Emerson also stated that in response to an initial offer, NI had chosen to conceal the offer from the investing public and had instead undertaken a large stock buy-back.

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IN RE NATIONAL INSTRUMENTS CORPORATION SECURITIES LITIGATION, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-national-instruments-corporation-securities-litigation-nysd-2024.