Jackson v. Microchip Technology Incorporated

CourtDistrict Court, D. Arizona
DecidedMarch 11, 2020
Docket2:18-cv-02914
StatusUnknown

This text of Jackson v. Microchip Technology Incorporated (Jackson v. Microchip Technology Incorporated) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jackson v. Microchip Technology Incorporated, (D. Ariz. 2020).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Ronald L. Jackson, No. CV-18-02914-PHX-JJT

10 Plaintiff, ORDER

11 v.

12 Microchip Technology Incorporated, et al.,

13 Defendants. 14 15 At issue are Defendants Microchip Technology Inc., Steve Sanghi, Ganesh Moorthy 16 and J. Eric Bjornholt’s Motion to Dismiss Amended Complaint and Motion to Strike 17 (Doc. 36, Mot.), to which Plaintiff Ronald L. Jackson filed a Response (Doc. 39, Resp.) 18 and Defendants filed a Reply (Doc. 42). The Court finds these matters appropriate for 19 resolution without oral argument. See LRCiv 7.2(f). 20 I. BACKGROUND 21 In this federal securities fraud class action, the Court appointed Ronald L. Jackson, 22 Trustee Under Agreement Dated 01/05/2012 by Ronald L. Jackson, as Lead Plaintiff under 23 Section 21D(a)(3)(B) of the Securities Exchange Act of 1934 (“the Act”) as amended by 24 the Private Securities Litigation Reform Act of 1995 (“the PSLRA”), 15 U.S.C. § 78u- 25 4(a)(3)(B), after finding he was the most adequate plaintiff under the PSLRA based on his 26 monetary loss of $214,240 allegedly resulting from Defendants’ wrongful conduct. 27 (Doc. 24.) Defendant Microchip Technology Inc. (“Microchip”) is a publicly-traded 28 company headquartered in Arizona that manufactures computer chips, and Defendant 1 Steve Sanghi is its Chief Executive Officer and Chairman of the Board of Directors, 2 Defendant Ganesh Moorthy is its President and Chief Operating Officer, and Defendant J. 3 Eric Bjornholt is its Senior Vice President and Chief Financial Officer. 4 On March 1, 2018, Microchip announced its intent to acquire Microsemi Corp., 5 another chip manufacturer, for $10.15 billion financed by $8.6 billion in new debt, by way 6 of a press release issued to the public and filed with the Securities and Exchange 7 Commission (“SEC”). Also on March 1, 2018, Sanghi, Moorthy, and Bjornholt “conducted 8 Analyst Day via an in-person presentation and question and answer session with investors 9 and at least 14 stock research analysts,” which was “also broadcast via conference 10 call/webcast for those persons who were not invited to attend” and a transcript of which 11 was filed with the SEC. (Doc. 32, Am. Compl. ¶ 202.) Plaintiff alleges that “[i]nvestors 12 and stock-analysts expressed concern with the cost of the transaction and Microchip’s 13 ability to service the $8.6 billion in debt.” (Am. Compl. ¶ 3.) Microchip publicly discussed 14 the benefits of acquiring Microsemi through a May 8, 2018 press release and conference 15 call; a May 10, 2018 Moorthy presentation; and 2018 SEC Forms 10-K and 8-K. On 16 May 29, 2018, Microchip issued a press release announcing that the acquisition closed, and 17 Microchip continued to communicate with the public about the acquisition through a 18 May 31, 2018 press release and conference call; a June 4, 2018 Moorthy presentation; a 19 June 6, 2018 Bjornholt presentation; and a June 12, 2018 Moorthy presentation. Plaintiff 20 alleges that “Defendants repeatedly assured investors that although the cost of the 21 transaction was steep, the debt would be paid through free cash flow generated by the 22 combined entities after the Merger.” (Am. Compl. ¶ 3.) 23 In the Amended Complaint, the operative pleading, Plaintiff alleges that Defendants 24 made 52 materially false statements or omissions—which the Court will refer to with “FS” 25 throughout this Order—in their communications with the public related to Microchip’s 26 acquisition of Microsemi.1 At base, Plaintiff contends that Defendants knowingly 27 misrepresented the amount of inventory in Microsemi’s distribution channel and thus the

28 1 In fact, the Amended Complaint identifies 53 materially false statements or omissions, but Plaintiff later withdrew one (FS 47). (Resp. at 17 n.19.) 1 net free cash flow available to pay the substantial debt incurred in the acquisition. 2 Specifically, Plaintiff alleges that 3 Defendants misrepresented that the debt was only a 4.7 multiple of [Earnings Before Interest, Tax, Depreciation, and Amortization (“EBITDA”)] (a proxy 4 for cash flow) to be generated by the Merger. Defendants failed to disclose that the $8.6 billion in debt was a five times multiple of cash flow expected 5 to be generated by the Acquisition. The Transaction closed on May 29, 2018, and thereafter Microchip and Microsemi reported operations on a 6 consolidated basis. Actual cash flow generated by the Merger, beginning May 29, 2018, was approximately $110 million less than represented to 7 Microchip’s investors because of Microsemi’s higher inventory levels. These higher levels were caused, according to Microchip, because historically 8 toward the end of each quarter Microsemi had sold inventory to distributors and end users for cash at discounted prices in excess of their current needs. 9 10 (Am. Compl. ¶ 4.) 11 Defendants explain that, 12 [p]rior to 2018, semiconductor companies recognized revenue in different ways: (1) sales to distributors could be recognized upon shipment to the 13 distributor, also referred to as “sell-in”; or (2) sales to distributors could be recognized upon reported resale of the product by the distributors to their 14 customers, the ultimate end users, also referred to as “sell-through.” Historically, Microsemi reported its net sales on a “sell-in” basis, and 15 Microchip generally reported its net sales on a “sell-through” basis. Recent changes in revenue recognition reporting rules now provide for uniform 16 reporting of net sales on a “sell-in” basis. Following the changes in revenue recognition reporting rules, Microchip provides [Generally Accepted 17 Accounting Principles (“GAAP”)] sell-in net sales and also provides [non- GAAP] sell-through information. 18 19 (Mot. at 5.) 20 Plaintiff alleges that Microchip ultimately concluded that Microsemi could 21 constructively inflate its revenue numbers in a certain reporting period through a practice 22 of “stuffing” its distribution channel with sales to distributors in amounts above the 23 distributors’ current needs. (Am. Compl. ¶ 6.) According to Plaintiff, Defendants 24 conducted extensive pre-acquisition due diligence and knew about Microsemi’s inventory 25 practices before the acquisition but failed to disclose to investors and stock analysts that 26 Microsemi’s “historically reported GAAP revenue was not representative of true user 27 demand.” (Am. Compl. ¶ 6.) And Defendants knew but failed to disclose that Microsemi’s 28 high inventory levels would “result in lower sell-through (non-GAAP) revenue, lower free 1 cash flow, lower EBITDA, and a lower ability to delever the combined company through 2 paying down debt.” (Am. Compl. ¶ 10.) 3 Ultimately, “[o]n August 9, 2018, a little more than two months after the Merger 4 closed, Defendants announced the truth that Microsemi had four plus months of inventory 5 in Microsemi’s distribution channel and, as a result, Microchip had $110 million less of 6 net free cash flow and higher debt leverage (5.0 v. 4.7 times EBITDA).” (Am. Compl. 7 ¶ 15.) As a result, Microchip would be unable to pay down its debt rapidly, and “Microchip 8 common stock fell $10.67 a share, causing significant damages to members of the Class” 9 who had purchased stock between March 2 and August 9, 2018. (Am. Compl. ¶¶ 1, 17.) 10 Generally, Plaintiff’s allegations of Defendants’ false statements and omissions fall 11 into four substantive categories: (1) statements having to do with the strength of 12 Microsemi’s business and the compelling nature of the merger between Microchip and 13 Microsemi (Resp. at 4 (listing FS 18, 20–21, 24, 27, 29, 37 & 46; Am. Compl. ¶¶ 270, 278, 14 291, 307, 318, 330, 337 & 357)); (2) statements regarding Microsemi’s inventory and sales 15 practices (Resp.

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