Kusnier v. Affirm Holdings, Inc.

CourtDistrict Court, N.D. California
DecidedAugust 14, 2025
Docket3:22-cv-07770
StatusUnknown

This text of Kusnier v. Affirm Holdings, Inc. (Kusnier v. Affirm Holdings, Inc.) 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
Kusnier v. Affirm Holdings, Inc., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 MARK KUSNIER, et al., Case No. 22-cv-07770-AMO

8 Plaintiffs, ORDER RE MOTION FOR LEAVE TO 9 v. FILE MOTION FOR RECONSIDERATION 10 AFFIRM HOLDINGS, INC., et al., Re: Dkt. No. 86 Defendants. 11

12 13 Before the Court is Plaintiffs’ motion for leave to file a motion for reconsideration of the 14 Court’s August 26, 2024 Order dismissing their second amended complaint for failure to 15 sufficiently allege facts supporting a strong inference of scienter. ECF 86 (“Mot.”). To obtain 16 such leave, Civil Local Rule 7-9(b) requires that Plaintiffs “specifically show reasonable diligence 17 in bringing the motion” and satisfy one of the following:

18 (1) That at the time of the motion for leave, a material difference in fact or law exists from that which was presented to the Court before 19 entry of the interlocutory order for which reconsideration is sought. The party also must show that in the exercise of reasonable diligence 20 the party applying for reconsideration did not know such fact or law at the time of the interlocutory order; or 21 (2) The emergence of new material facts or a change of law occurring after the time of such order; or 22 (3) A manifest failure by the Court to consider material facts or dispositive legal arguments which were presented to the Court 23 before such interlocutory order. 24 Civil L.R. 7-9(b). 25 Plaintiffs rely on subsection (b)(3), contending that there was a “manifest failure by the 26 Court to consider material facts or dispositive legal arguments” presented in the motion to dismiss 27 briefing. Mot. at 6, 9. Specifically, Plaintiffs argue that the Court (1) disregarded Defendants’ 1 inference, (3) disregarded statements of confidential witnesses, and (4) discounted the temporal 2 proximity of Linford’s false statements to inconsistent information. Id. at 9-17. Finding no issue 3 with the timing of Plaintiffs’ motion, and finding leave appropriate under Civil Local Rule Rule 7- 4 9(b)(3), the Court addresses each substantive issue Plaintiffs raised in their motion in turn.1 5 With respect to whether statements by Defendants showing awareness of interest rate risks 6 supported an inference of scienter, the Court determined:

7 Kusnier’s contention that Defendants’ statements themselves raise an inference of actual knowledge of falsity is unavailing. The 8 statements Kusnier points to in his opposition are not the 11 statements identified as the basis for his claims. See ECF 80 at 25- 9 26 (citing ECF 72 ¶¶ 29-30, 32, 33-34). Kusnier has thus made no showing that the 11 statements at issue are themselves indicative of 10 scienter, and the Court declines to allow Kusnier to use his opposition brief as an opportunity to re-frame his claims. See Petrie 11 v. Elec. Game Card Inc., No. SACV 10-00252 DOC (RNBx), 2011 WL 165402, at *4 n.2 (C.D. Cal. Jan. 12, 2011) (citation omitted) 12 (“[I]t is axiomatic that the complaint may not be amended by briefs in opposition to a motion to dismiss.”). 13 14 Order at 15. 15 Plaintiffs contend the statements referenced in paragraphs 28-34 of the SAC “explained in 16 particularized detail why Defendants’ own statements showed an acute awareness of interest rate 17 risks.” Mot. at 11. Those paragraphs read: 18 28. Defendants’ own statements concede their Class Period knowledge of the misrepresented and concealed facts, raising 19 a strong inference of scienter. Throughout the Class Period, Defendants touted their knowledge and awareness of interest rate 20 risks or reckless disregard for the risk of rising interest rates and their negative impact on the Company’s funding costs in SEC filings 21 as well as commentary during public events. 22 29. Linford, in particular, spoke with a great degree of specificity on this topic throughout the Class Period. For example, 23 Linford assuaged investors’ rate fears just after United States Secretary of the Treasury Janet Yellen warned in early 2021 that the 24 Federal Funds Rate would soon need to increase. On May 11, 2021, 25 1 While the motion is styled as one for leave to seek reconsideration, Plaintiffs ask that “the Court 26 grant Plaintiffs’ Motion for leave to file a motion for reconsideration of the Court’s August 26, 2024 Order and deny Defendants’ Motion to Dismiss.” Mot. at 17. The Court therefore construes 27 Plaintiffs’ filing as a combined motion for leave and for reconsideration. In analyzing the issues Linford attended the MoffettNathanson Payments, Processors, and 1 IT Services Summit. At this conference call, Linford was specifically asked about “comments out of the Fed, Yellen, et 2 cetera” concerning how the rising rate environment would affect Affirm’s business, and Linford responded that Affirm had stress 3 tested its revenue model and, based on the results of those tests, the Company was “well positioned to succeed in any rate environment 4 that we’ve seen over the past 20 years.” He further stated that: 5 We believe there’s a real misconception about interest rates in Affirm out there right now. We 6 believe that we’re really well positioned to succeed in any rate environment that we’ve seen over the 7 past 20 years. 8 There -- we have gone back and stress tested our model, business model, revenue model, the level of 9 what we call contribution profit or revenue less transaction cost, we’ve gone back 20 years of rates 10 and stimulated it through our business and we’re good, which means we can get it for like 650 basis 11 points of rates. 12 And like while we believe that like everybody that rates won’t stay at zero forever and that we are going 13 to have to start reacting to a higher rate environment, we think the first derivative, i.e., the change in rates it 14 just doesn’t impact us. Seventy-five percent of our portfolio is funded with fixed rate or no polluting -- 15 no interest rate exposure at all and the 25% that’s funded with interest rates, but that we’re in 16 complete control over. So, in the short-term kind of first derivatives shocks 17 doesn’t worry us at all. And longer-term we can go back over two decades and still be good with respect 18 to our unit economics and that’s before we pull any of our cost or revenue levers, which are huge. So, 19 on the revenue side, look, the higher the break the more valuable a 0% offer is. It’s just definitional, 20 right? If you’re a consumer -- if you’re a consumer and rates are 0, a 0% offer is less compelling as when 21 the rates are at 3%, 4% or 5%. So we know that the product is more valuable and how we monetize it is a 22 thing that we can do either through the merchant, which we tested during COVID where we had to 23 tighten credit and our product was valuable enough that merchants chose to continue to pay us more 24 merchant fees to support the same level of approvals. And we think the same will hold out in a higher rate 25 environment. 26 30. The Federal Funds Rate was over 5% between 2006 and 2007. It did not cross over 5% during the Class Period. It has 27 not come close to “650 basis points.” Given Linford’s affirmative be little to no short-term impact on Affirm from an increase in 1 interest rates, Affirm’s funding costs should not have unexpectedly increased, as the Company ultimately admitted they would when it 2 announced disastrous financial results for the second quarter of 2023 on February 8, 2023. There are only two possible inferences to be 3 made based on Linford’s guarantee based on the stress tests results: either (1) he lied about conducting the stress tests or (2) he knew 4 from their results that Affirm could not withstand an increase in rates to 4% or more, and recklessly ignored the prospect of 5 misleading investors by withholding that crucial information. Baseless assertions that the stress tests were correct at the time they 6 were conducted are utterly illogical. Either the business could survive rate hikes of over 4% or it could not.

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