In re SVB Financial Group Securities Litigation

District Court, N.D. California·Decided November 30, 2023·No. 5:23-cv-01097·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 In re SVB Financial Group Securities Case No. 3:23-cv-01097-JD

8 Litigation ORDER CONSOLIDATING CASES, 9 APPOINTING LEAD PLAINTIFF, AND SETTING CASE SCHEDULE 10

12 The Court orders as follows in this securities putative class action. 13 I. CONSOLIDATION 14 Plaintiffs Mahendra Sreerama, Tamir Einy, KBC Asset Management NV (KBC), Norges 15 Bank (Norges), and Sjunde AP-Fonden (AP7) ask to consolidate this case with six later-filed cases 16 in this District: Snook v. SVB Financial Group (3:23-cv-01173), Siddiqui v. Becker (3:23-cv- 17 01228), Hialeh Employees v. Becker (3:23-cv-01697), International Union of Operating 18 Engineers v. SVB (3:23-cv-01962), Stevenson v. Becker (4:23-cv-02277), and Rossi v. Becker 19 (3:23-cv-02335). See Dkt. Nos. 31, 35, 38, and 44. The motions are unopposed. 20 Federal Rule of Civil Procedure 42(a) permits consolidation of “actions involving a 21 common question of law or fact.” Fed. R. Civ. P. 42(a). “Consolidation is within the broad 22 discretion of the district court.” In re Adams Apple, Inc., 829 F.2d 1484, 1487 (9th Cir. 1987). 23 For Stevenson (4:23-cv-02277) and Rossi (3:23-cv-02335), the Court will determine 24 whether consolidation is appropriate only after resolution of the remand issue, which remains 25 pending before another court in this District. See Dkt. No. 52. Consolidation of these cases is 26 ordered: Vanipenta (3:23-cv-01097), Snook (3:23-cv-01173), Siddiqui (3:23-cv-01228), Hialeh 27 Employees (3:23-cv-01697), International Union of Operating Engineers (3:23-cv-01962). 1 of law and fact. They allege substantially similar claims under the Exchange Act and Securities 2 Act against common defendants, across overlapping class periods, and concerning the same 3 conduct. The cases are consolidated into the lowest-numbered case, 3:23-cv-01097, which will be 4 re-captioned In re SVB Financial Group Securities Litigation. The other four cases will be closed. 5 II. APPOINTMENT OF LEAD PLAINTIFF AND LEAD COUNSEL 6 Putative class members filed four competing motions seeking appointment as lead plaintiff 7 under the Private Securities Litigation Reform Act (PSLRA), 17 U.S.C. § 78u-4(a)(3)(B)(i). Dkt. 8 Nos. 31, 35, 38, and 44. Two parties -- Sreerama and Einy -- no longer seek appointment as lead 9 plaintiff. See Dkt No. 46 (Einy’s notice of non-opposition); Dkt. No 47 (Sreerama’s notice of 10 withdrawal). Two proposed lead plaintiffs remain: KBC, and a group comprising Norges and 11 AP7. Dkt. Nos. 38, 44. 12 The PSLRA establishes a three-step process for appointing a lead plaintiff. 15 U.S.C. 13 § 78u-4(a)(3)(B). First, the plaintiff in the first-filed action must “publiciz[e] pendency of the 14 action, the claims made and the purported class period” in a “widely circulated national business- 15 oriented publication or wire service.” In re Cavanaugh, 306 F.3d 726, 729 (9th Cir. 2002) (citing 16 15 U.S.C. § 78u-4(a)(3)(A)). The parties do not dispute that this step was adequately completed 17 by plaintiff Vanipenta. See Dkt. No. 32-1. 18 The Court next considers the “potential lead plaintiffs one at a time, starting with the one 19 who has the greatest financial interest, and continuing in descending order if and only if the 20 presumptive lead plaintiff is found inadequate or atypical.” Cavanaugh, 306 F.3d at 732. The 21 Court “must calculate each potential lead plaintiff’s financial interest in the litigation” using a 22 method that is “both rational and consistently applied.” Cavanaugh, 306 F.3d at 730 n.4. KBC 23 has suffered losses of approximately $8.9 million on a LIFO basis. Dkt. No. 38-3. Norges and 24 AP7 have suffered losses of approximately $138.4 and $23.5 million on a LIFO basis, 25 respectively, for a combined loss of approximately $161.8 million. Dkt. No. 44-3. 26 Because Norges and AP7 have the largest financial interest in the litigation, the Court 27 “focus[es its] attention on [those] plaintiff[s] and determine . . . whether [they] satisf[y] the 1 F.3d at 730. As established by Norges and AP7’s pleadings, Dkt. No. 44 at 1-12, they have made 2 a prima facie showing of typicality and adequacy. Consequently, the group comprising Norges 3 and AP7 is the presumptive “most adequate plaintiff” under the PSLRA. 15 U.S.C. § 78u- 4 4(a)(3)(B)(iii)(I). 5 In the third and final step, other plaintiffs may rebut the presumptive lead plaintiff’s 6 showing that it satisfies Rule 23’s typicality and adequacy requirements. Cavanaugh, 306 F.3d at 7 730. Competing movants must point to evidence of inadequacy. In re Mersho, 6 F.4th 891, 901 8 (9th Cir. 2021). 9 KBC, also seeking appointment as lead plaintiff, says that Norges and AP7 are improper 10 lead plaintiffs because they are a group lacking a genuine, pre-existing relationship. Dkt. No. 50 11 at 3. KBC did not proffer any independent evidence on this score, and relies solely on critiquing 12 the joint Norges/AP7 declaration. Id. at 4-7. 13 KBC’s objection is not well taken. Neither the PSLRA, nor this Court’s prior rulings in In 14 re Stitch Fix Securities Litigation and In re Zoom Securities Litigation, categorically bars groups 15 from appointment as lead plaintiff. The consideration of “pre-litigation relationships or cohesion” 16 must be tethered, in some way, to the burden-shifting process established in the PSLRA. Mersho, 17 6 F.4th at 901-2. The Court evaluates group cohesion as part of the adequacy analysis. Id. If 18 evidence indicates group members might not “work together well” or “be able to control counsel,” 19 they may not adequately represent class member interests. In Stitch Fix, the Court declined to 20 permit aggregation and lead plaintiff status for a group where the facts established that the “lawyer 21 [would] call the shots.” In re Stitch Fix, Inc. Sec. Litig., 393 F. Supp. 3d 833, 835-6 (N.D. Cal. 22 2019). So, too, in Zoom, where the Court held that a lawyer-created group of individual investors 23 with no pre-existing relationships would be an inadequate plaintiff, because the group would be 24 directed by lawyers. Order re Lead Plaintiff and Lead Counsel, In re Zoom Sec. Litig., No. 3:20- 25 cv-02353, Dkt. No. 56 (N.D. Cal. Nov. 4, 2020). 26 KBC has not demonstrated that any such concerns may be present here. It has not shown 27 that the group of Norges and AP7 is the product of lawyer-driven efforts. It bears mention that 1 eclipse those of other movants. Dkt. No. 44-3. KBC also did not demonstrate Norges and AP7 2 aggregated their claims at the behest of counsel. Their joint declaration states they sought 3 litigation partners of their own volition. Dkt. No. 44-4 ¶¶ 10-12. This effectively forecloses 4 KBC’s complaint that the declaration “never address[es] how the group actually came together 5 (i.e., was it through their lawyers’ discussions?).” Dkt. No. 50 at 7. KBC offers no evidence in 6 support of a contrary conclusion, and mere conjecture will not rebut the presumption. See Mersho, 7 6 F.4th at 901. KBC says that the joint declaration is silent on why Norges and AP7 retained two 8 law firms, Dkt No. 50 at 7, but that circumstance is of little moment.

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