In re SVB Financial Group Securities Litigation

CourtDistrict Court, N.D. California
DecidedJune 13, 2025
Docket5:23-cv-01097
StatusUnknown

This text of In re SVB Financial Group Securities Litigation (In re SVB Financial Group 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 SVB Financial Group Securities Litigation, (N.D. Cal. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 IN RE SVB FINANCIAL GROUP 4 SECURITIES LITIGATION Case No. 23-cv-01097-NW 5 ORDER DENYING EXCHANGE 6 DEFENDANTS’, KPMG, AND SECURITIES DEFENDANTS’ 7 MOTIONS TO DISMISS 8 Re: ECF Nos. 121, 122, 123, 124, 125 9 This is a putative class action for securities fraud against former officers, directors, 10 underwriters, and an auditor of Silicon Valley Bank Financial Group (“SVBFG”), the parent 11 company of Silicon Valley Bank (“SVB” or the “Bank”) (collectively, “Defendants”). Lead 12 Plaintiffs Norges Bank and Sjunde AP-Fonden filed a Consolidated Amended Complaint (“CAC”) 13 alleging violations of Sections 11, 12, and 15 of the Securities Act of 1933 (“Securities Act”) and 14 Sections 10(b), 20(a), and 20A of the Securities Exchange Act of 1934 (“Exchange Act”). CAC, 15 ECF No. 88. 16 Different configurations of defendants filed three motions to dismiss. Defendants to the 17 Exchange Act counts, SVB CEO Gregory W. Becker and CFO Daniel J. Beck (“Exchange Act 18 Defendants”), filed a motion specifically challenging those counts. ECF Nos. 121 (“Exch. Defs 19 MTD”), 138 (“Exch. Defs Reply”). KPMG, SVB’s outside auditor, filed a motion to dismiss the 20 single count against them under the Securities Act. ECF Nos. 123 (“KPMG MTD”), 139 21 (“KPMG Reply”). Because the Exchange Act Defendants were also subject to Securities Act 22 counts, Becker and Beck joined fellow executive Karen Hon (collectively the “Executive 23 Defendants”), the Underwriters Defendants,1 and the Director Defendants2 in their motion to 24 25 1 The following Defendants were underwriters to one or more of the Offerings: Goldman Sachs & Co. LLC (“Goldman”); BofA Securities, Inc. (“BofA”); Keefe, Bruyette & Woods, Inc. (“Keefe”); 26 and Morgan Stanley & Co. LLC (“Morgan Stanley”) (collectively, the “Underwriter Defendants”). CAC ¶ 380. 27 2 The following SVB directors (the “Director Defendants”) were each a signatory of the 1 dismiss the Securities Act claims. ECF Nos. 125 (“Secs. Defs MTD”); 140 (“Secs. Defs Reply”). 2 Plaintiffs opposed the motions. ECF Nos. 134 (“Exch. Opp.”), 135 (“KPMG Opp.”), and 136 3 (“Secs. Opp.”). For the reasons discussed below, the Court DENIES all three motions. 4 I. BACKGROUND 5 Plaintiffs’ Complaint is divided into two independent parts and is based on two, 6 independent sets of claims. See generally CAC. In Part One, Plaintiffs assert claims under 7 Exchange Act Sections 10(b), 20(a), and 20A against Becker and Beck. Id. ¶ 1. Plaintiffs bring 8 the Exchange Act claims “individually and on behalf of all persons and entities who purchased or 9 otherwise acquired the common stock of Silicon Valley Bank Financial Group between January 10 21, 2021, and March 10, 2023, inclusive (the “Class Period”).” Id. In Part Two, Plaintiffs assert 11 claims under the Securities Act Sections 11, 12(a)(2) and 15 against former SVB executives, 12 directors, underwriters, and KPMG. Id. ¶ 19. Plaintiffs bring the Securities Act claims 13 individually and on behalf of the persons and entities who purchased SVB securities in, or 14 traceable to, one or more of the Bank’s eleven securities offerings (the “Offerings” or an 15 “Offering”) during the Class Period. Id. Each Offering was completed pursuant to a registration 16 statement filed by SVBFG, on November 15, 2019 (the “Registration Statement”) , as well as 17 pursuant to prospectus supplements issued for each Offering (the “Prospectus Supplement,” 18 together with the Registration Statement, the “Offering Documents”). 19 The breakdown of all Plaintiffs’ claims is shown in the table below. 20 Exchange Act Securities Act 21 § 10(b) § 20(a) § 20A § 11 § 12(a)(2) § 15 Gregory W. Becker Count I Count II Count III Count IV Count VI 22 Daniel J. Beck Count I Count II Count III Count IV Count VI Karen Hon Count IV Count VI 23 Underwriter Defendants Count IV Count V Director Defendants Count IV Count VI 24 KPMG LLP Count IV 25 26

27 Burr, John Clendening, Richard Daniels, Alison Davis, Roger Dunbar, Joel Friedman, Jeffrey 1 A. Facts 2 1. The Failure of SVB 3 In its report following SVB’s collapse, the Federal Reserve (“the Fed”) described SVBFG 4 as: a large bank holding company with approximately $212 billion in 5 total assets when it failed in March 2023. SVBFG provided financial services predominantly to companies in the technology and life 6 sciences sectors. Between 2019 and 2021, SVBFG tripled in size as it benefited from rapid deposit inflows during rapid venture capital 7 (VC) and technology sector growth in a period of exceptionally low interest rates. These deposits were largely uninsured, and SVBFG 8 invested them primarily in securities with longer-term maturities. In 2022, as interest rates began to rise, SVBFG saw deposit outflows and 9 a rapid increase in unrealized losses on those securities. 10 Exch. Defs RJN, Ex. 1, ECF No. 122-1 (“Fed Report”) at 3. The Report explains that “as 11 the risks to the firm’s balance sheet mounted, SVBFG” attempted to correct course on March 8, 12 2023, by “restructure[ing] its balance sheet” (id. at 4) and making the following announcements:

13 First, SVB disclosed that the Bank was forced to sell “substantially all of its available for sale securities portfolio” for a nearly $2 billion 14 dollar loss. Second, SVB disclosed that, even after the fire-sale of its entire AFS portfolio, the Bank’s liquidity shortcomings had become 15 so severe as a result of rising interest rates that it needed to raise another approximately $2.25 billion through various stock offerings. 16 SVB also admitted that, even with the capital raise, there would be a “payback period of approximately three years” to make up for this 17 loss. Third, SVB disclosed that it was lowering its net interest income guidance for both the first quarter of 2023 and the full year. 18 CAC ¶ 202 (emphasis in original). Following this news, the price of SVB common stock declined 19 more than 60% in a single day. Id. ¶ 204. As one analyst explained, “SVB—which for months 20 has been adamant that it wouldn’t significantly restructure its balance sheet—stunned investors 21 Wednesday when it said it would issue $2.25 billion of shares and booked a $1.8 billion loss on 22 the sale of a large part of its available-for-sale securities.” Id. (quoting Bloomberg, “SVB Is in 23 Sale Talks After Capital Raising Failed, CNBC Says” (March 10, 2023), 24 https://www.bloomberg.com/news/articles/2023-03-10/svb-in-talks-to-sell-itself-after-capital- 25 raise-fails-cnbc-says.). SVB’s customers reacted accordingly “to these disclosures . . . and began 26 to rapidly withdraw their deposits.” Id. ¶ 205. “In total, depositors attempted to withdraw more 27 than $40 billion from their accounts at SVB on March 9, 2023.” Id. (emphasis in original). 1 SVB’s demise quickly followed. Id. ¶ 206. On March 10, 2023, the NASDAQ exchange 2 suspended trading in SVB stock; the California Department of Financial Protection and Innovation 3 closed down the Bank and appointed the Federal Deposit Insurance Corporation as receiver. Id. 4 On March 17, 2023, SVB filed for Chapter 11 bankruptcy protection, rendering all its issued 5 securities essentially valueless. Id. ¶ 210. 6 2. Defendants’ Alleged False Representations and Omissions 7 The principal issue in this case is whether the Defendants made materially false 8 representations or omissions about SVB that induced Plaintiffs to buy securities in the Bank. 9 Plaintiffs allege that, given SVB’s business as a lender and its concentration of uninsured deposits, 10 the market was “acutely focused on SVB’s ability to manage its expanding risks.” Exch. Opp. at 11 3. Consequently, any misrepresentations as to the health of SVB’s balance sheet and internal 12 controls would and did mislead investors. See Secs. Opp. at 4.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Scientific-Atlanta, Inc. v. Rochelle Phillips
374 F.3d 1015 (Eleventh Circuit, 2004)
Tellabs, Inc. v. Makor Issues & Rights, Ltd.
551 U.S. 308 (Supreme Court, 2007)
Uttecht v. Brown
551 U.S. 1 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
United States v. Steven M. Self
2 F.3d 1071 (Tenth Circuit, 1993)
In Re Worlds Of Wonder Securities Litigation
35 F.3d 1407 (Ninth Circuit, 1994)
In Re Glenfed, Inc. Securities Litigation
42 F.3d 1541 (Ninth Circuit, 1994)
Lee v. City Of Los Angeles
250 F.3d 668 (Ninth Circuit, 2001)
Vess v. Ciba-Geigy Corp. USA
317 F.3d 1097 (Ninth Circuit, 2003)
Zucco Partners, LLC v. Digimarc Corp.
552 F.3d 981 (Ninth Circuit, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
In re SVB Financial Group Securities Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-svb-financial-group-securities-litigation-cand-2025.