In re Super Micro Computer, Inc. Securities Litigation

CourtDistrict Court, N.D. California
DecidedAugust 5, 2025
Docket5:24-cv-06147
StatusUnknown

This text of In re Super Micro Computer, Inc. Securities Litigation (In re Super Micro Computer, 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 Super Micro Computer, Inc. Securities Litigation, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 SAN JOSE DIVISION 7 8 IN RE SUPER MICRO COMPUTER, INC. Case No. 5:24-cv-06147-EJD SECURITIES LITIGATION 9 ORDER DENYING MOTION FOR RECONSIDERATION 10 11 Re: ECF No. 149 12

13 Before the Court is Crain Walnut Shelling, LP’s motion for reconsideration. Crain Walnut 14 asks the Court to reconsider its various lead plaintiff selection orders, to vacate its appointment of 15 Universal-Investment-Gesellschaft mbH as lead plaintiff, and to instead appoint Crain Walnut as 16 lead plaintiff. The Court finds this motion suitable for decision without oral argument under Local 17 Rule 7-1(b) and, for the following reasons, DENIES reconsideration. 18 I. BACKGROUND 19 This case began nearly a year ago when Joseph Averza filed suit against Defendant Super 20 Micro Computer, Inc. and certain of its executives. ECF No. 1. Averza alleged that Super Micro 21 had committed securities fraud, triggering those provisions of the Private Securities Litigation 22 Reform Act (PSLRA) that govern appointment of a lead plaintiff. 23 The Court followed the PSLRA’s three-step process for selecting lead plaintiff. First, the 24 Court waited for Averza to provide public notice of his action so that other members of the 25 putative class could have the chance to seek appointment as lead plaintiff. In re Cavanaugh, 306 26 F.3d 726, 729 (9th Cir. 2002). Ten different lead plaintiff groups responded to Averza’s notice by 27 moving for appointment. ECF Nos. 17, 19, 23, 26, 30, 37, 38, 43, 48, 49. Eight withdrew in short 1 Second, the Court selected the “presumptively most adequate plaintiff” from among the 2 remaining lead plaintiff applicants. In re Cavanaugh, 306 F.3d at 729–30. Applying the 3 PSLRA’s criteria, the Court held Crain Walnut to be the presumptive lead plaintiff. ECF No. 99. 4 Third, the Court allowed Universal an opportunity to rebut the presumption in favor of 5 Crain Walnut. In re Cavanaugh, 306 F.3d at 730. Because Universal had raised substantial 6 questions about Crain Walnut’s adequacy, the Court permitted limited discovery into Crain 7 Walnut’s adequacy and typicality. ECF No. 99; 15 U.S.C. § 78u-4(a)(3)(B)(iv). Then, once 8 discovery closed, the Court received supplemental briefs from Crain Walnut and Universal, and it 9 held a hearing on the matter. ECF Nos. 111, 114, 123. Finally, based on the discussion at 10 hearing, the Court requested and received a second set of supplemental briefs. ECF Nos. 130, 11 132. After thoroughly examining the lead plaintiff issue with the benefit of both discovery and 12 voluminous briefing from Crain Walnut and Universal, the Court ultimately concluded that 13 Universal had rebutted the presumption that Crain Walnut was the most adequate plaintiff. ECF 14 No. 142. Accordingly, the Court denied Crain Walnut’s lead plaintiff motion. Id. 15 At that point, the PSLRA required the Court to return to the second step of the lead 16 plaintiff selection process to identify a new presumptive lead plaintiff with Crain Walnut off the 17 board. In re Cavanaugh, 306 F.3d at 731. Since Universal was the only remaining plaintiff 18 actively vying for the lead plaintiff position, the Court could have appointed Universal as lead 19 plaintiff then. But the Court did not. Instead, in order to ensure a robust lead plaintiff selection 20 process, the Court offered the previously withdrawing lead plaintiff candidates an opportunity to 21 re-notice their motions and once again challenge Universal for the position. Id. at 21. One 22 candidate, Valikhan Kunakbayev, re-noticed his motion before withdrawing a second time. ECF 23 Nos. 143, 146. On the same day that Kunakbayev withdrew, Crain Walnut asked for leave to file 24 a motion for reconsideration of the Court’s earlier order. ECF No. 147. 25 Since Kunakbayev withdrew, the Court appointed Universal as lead plaintiff. ECF No. 26 148. At the same time, the Court granted leave for Crain Walnut to file a motion for 27 reconsideration, noting that if Crain Walnut succeeded, it would vacate Universal’s appointment 1 II. LEGAL STANDARD 2 Courts may reconsider their interlocutory orders “at any time prior to final judgment.” 3 Amarel v. Connell, 102 F.3d 1494, 1515 (9th Cir. 1996). Reconsideration is an “extraordinary 4 remedy” that interferes with “interests of finality and conservation of judicial resources.” Kona 5 Enters. v. Est. of Bishop, 229 F.3d 977, 890 (9th Cir. 2000). As such, it should be granted only 6 “sparingly,” when (a) there is newly discovered evidence, (b) clear error, or (c) an intervening 7 change in law. Id.; see also Civil L.R. 7-9(b). 8 III. DISCUSSION 9 Crain Walnut’s arguments for reconsideration fall into four main categories. First, Crain 10 Walnut takes issue with the standard of proof that the Court applied when concluding Universal 11 had rebutted the presumption of adequacy. Second, Crain Walnut objects that the Court did not 12 follow the PSLRA’s procedural safeguards. Third, Crain Walnut disagrees with the Court’s 13 factual findings and the weight that the Court assigned those findings. Finally, Crain Walnut 14 claims that the Court applied the law inconsistently. The Court takes each in turn. 15 A. Standard of Proof 16 Under the PSLRA, once a plaintiff is presumed to be the most adequate at the second step 17 of the selection process, that presumption can be rebutted “only upon proof” of inadequacy or 18 atypicality. 15 U.S.C. § 78u-4(a)(3)(B)(iii)(II). This requires affirmative evidence from 19 competing plaintiffs who seek to rebut the presumption. In re Mersho, 6 F.4th 891, 901 (9th Cir. 20 2021) (“[C]ompeting movants must point to evidence of inadequacy.”). But the PSLRA does not 21 specify a standard of proof for rebutting the presumption; it says nothing about how much 22 evidence is needed or how convincing a competing plaintiff must be. Rather, the PSLRA says 23 only that “proof” is necessary. 15 U.S.C. § 78u-4(a)(3)(B)(iii)(II). Therefore, the Court must 24 “prescribe” a standard of proof. Herman & MacLean v. Huddleston, 459 U.S. 375, 389 (1983). 25 Based on its review of relevant Ninth Circuit precedent and the general principles surrounding 26 choice of a standard of proof, the Court held that Universal could meet its burden to rebut the 27 presumption by demonstrating, with evidence, that “genuine and serious doubt” exists about Crain 1 Crain Walnut contends that the genuine and serious doubt standard is erroneous both as a 2 matter of first principles and Ninth Circuit precedent. From its perspective, the PSLRA requires a 3 preponderance of the evidence to rebut the presumption of adequacy. As the Court discusses in a 4 later section, this is not grounds for reconsideration because Universal successfully rebuts the 5 presumption even under a preponderance standard. Infra Section III.C. That said, Crain Walnut 6 has also not shown that the genuine and serious doubt standard is clearly erroneous. 7 To begin, no party has cited, nor has the Court uncovered in its own research, any 8 precedential decision from the Ninth Circuit or any other circuit that squarely establishes the 9 standard of proof for rebutting the PSLRA’s presumption. So, identifying the proper standard 10 requires statutory interpretation. Crain Walnut focuses on the PSLRA’s use of the words “upon 11 proof.” 15 U.S.C. § 78u-4(a)(3)(B)(iii)(II).

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Bluebook (online)
In re Super Micro Computer, Inc. Securities Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-super-micro-computer-inc-securities-litigation-cand-2025.