Lowe v. Tandem Diabetes Care, Inc.

CourtDistrict Court, S.D. California
DecidedApril 30, 2024
Docket3:23-cv-01657
StatusUnknown

This text of Lowe v. Tandem Diabetes Care, Inc. (Lowe v. Tandem Diabetes Care, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lowe v. Tandem Diabetes Care, Inc., (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 SOUTHERN DISTRICT OF CALIFORNIA 11 12 CAREY LOWE, individually and on Case No.: 3:23-cv-01657-H-BLM behalf of all others similarly situated, 13 ORDER: Plaintiff, 14 v. GRANTING DEFENDANTS’ 15 MOTION TO DISMISS WITH TANDEM DIABETES CARE INC., 16 LEAVE TO AMEND JOHN F. SHERIDAN, AND LEIGH A.

17 VOSSELLER,

18 Defendants. [Doc. No. 21.] 19 20 On February 1, 2024, Co-Lead Plaintiffs Mason Raines, Thomas O. Martel, and 21 Linna Rae Martel (“Plaintiffs”), filed an amended complaint (“AC”) alleging that 22 Defendants Tandem Diabetes Care Inc., John F. Sheridan, and Leigh A. Vosseller 23 (collectively, “Defendants”) violated federal securities laws. (Doc. No. 16, AC.) On 24 March 11, 2024, Defendants filed a motion to dismiss Plaintiffs’ AC for failure to state a 25 claim. (Doc. No. 21.) On March 27, 2024, Plaintiffs filed a response in opposition to 26 Defendants’ motion to dismiss. (Doc. No. 22.) On April 10, 2024, Defendants filed their 27 reply. (Doc. No. 23.) The Court, pursuant to its discretion under Local Rule 7.1(d)(1), 28 submitted the motion on the parties’ papers. (Doc. No. 24.) On April 24, 2024, Plaintiffs 1 filed a notice of supplemental authority in support of their opposition to Defendants’ 2 motion to dismiss. (Doc. No. 25.) On April 25, 2024, Defendants filed a notice of 3 supplemental authority in support of their motion to dismiss. (Doc. No. 26.) For the 4 reasons below, the Court grants Defendants’ motion to dismiss with leave to amend. 5 BACKGROUND 6 The following factual background is taken from the allegations in Plaintiffs’ AC. 7 This is a securities class action against Tandem Diabetes Care, Inc. (“Tandem” or the 8 “Company”) and two of its officers – John F. Sheridan and Leigh A. Vosseller (together, 9 the “Individual Defendants”) – under Sections 10(b) and 20(a) of the Securities Exchange 10 Act of 1934 (the “Exchange Act”) and Rule 10b-5, promulgated thereunder. (AC ¶¶ 97– 11 112.) Defendant John F. Sheridan (“Sheridan”) was Tandem’s President, Chief Executive 12 Officer, and Director of Tandem. (Id. ¶ 17.) Defendant Leigh A. Vosseller (“Vosseller”) 13 served as Tandem’s Executive Vice President, Chief Financial Officer, and Treasurer. (Id. 14 ¶ 18.) Plaintiffs bring this action on behalf of all persons and entities who purchased 15 Tandem common stock between August 3, 2022 and November 2, 2022, inclusive (the 16 “Class Period”). (Id. ¶ 1.) 17 Tandem is a medical device company based in San Diego, California, that focuses 18 on diabetes management. (Id. ¶¶ 16, 23.) Tandem primarily manufactures and sells insulin 19 pumps for diabetic patients. (Id. ¶ 2.) Approximately 75% of its sales occur in the United 20 States. (Id. ¶ 24.) Tandem originates its sales from first-time customers and renewals (i.e., 21 customers renewing the pumps they already own). (Id.) For Tandem’s U.S. customers, 22 health insurance plans will reimburse customers for Tandem pumps once customers satisfy 23 their yearly deductibles. (Id. ¶ 65.) This means that demand for Tandem’s pump is lowest 24 at the beginning of the year when deductibles reset and then sales generally increase in the 25 third and fourth quarters when more potential customers meet their insurance deductibles 26 towards the end of the year. (Id. ¶¶ 62, 65.) Defendants refer to this purchasing cycle as 27 “seasonality.” (See id. ¶ 51.) 28 In the first quarter of 2022, the Company reported its 2021 earnings and issued its 1 sales guidance for 2022. (Id. ¶ 25.) Tandem projected sales in the range of $845 million 2 to $860 million, including U.S. sales of $630 million to $640 million, and adjusted 3 EBITDA of 14-15% of sales. (Id. ¶¶ 25–26, 31.) Plaintiffs allege the Company’s estimates 4 for 2022 were above analysts’ revenue estimates of $827 million, and analysts generally 5 reacted positively to Tandem’s year-end earnings and 2022 forecast announcements. (Id. 6 ¶¶ 26–27.) 7 During the second quarter of 2022, Tandem reported its financial earnings for the 8 first quarter of 2022. (Id. ¶ 29.) Tandem’s revenue for the quarter was $175.9 million, 9 beating analyst expectations of $168.2 million. (Id.) Tandem identified pandemic-related 10 conditions, such as labor shortages in physicians’ offices, as a negative headwind that the 11 Company expected to continue into the second quarter of 2022. (Id. ¶ 30.) The Company 12 also revised in financial guidance for the year and increased estimated sales to $850 million 13 to $865 million. (Id. ¶ 31.) 14 Plaintiffs allege three significant adverse market conditions (“Three Headwinds”) 15 existed during the second quarter of 2022, worsened through the third quarter and the 16 remainder of the Class Period, of which Defendants were aware, but did not disclose to 17 investors or the public. (Id. ¶ 34.) The Three Headwinds were (1) pandemic-related 18 conditions, (2) macroeconomic factors, and (3) competition. (Id.) Regarding the 19 pandemic, COVID-19 had caused, among other things, absenteeism and staffing shortages 20 in physician offices. (Id.) Macroeconomic factors referred to unemployment, inflation, 21 and potential customers’ lack of disposable income to spend on new pumps. (Id.) And 22 competition existed from new insulin pumps entering the market from Tandem’s 23 competitors, specifically Insulet and Medtronic. (Id.) In particular, Plaintiffs allege 24 Defendants concealed and materially downplayed the negative market conditions Tandem 25 faced with respect to competition. (Id. ¶¶ 60–61, 63, 68.) 26 Plaintiffs’ allegations regarding the adverse market conditions rely on statements 27 from two former employees: (1) former employee 1 (“FE1”), a territory manager at 28 Tandem from January 2020 to July 2023 who oversaw salespeople in the northwestern 1 region of the U.S.; and (2) former employee 2 (“FE2”), a Tandem sales representative who 2 sold Tandem’s insulin pumps to customers in Canada. (Id. ¶¶ 35, 38.) FE1 allegedly 3 communicated his or her concerns to senior management about the negative and 4 intensifying impact that the Three Headwinds were having on pump sales, but management 5 ignored FE1’s warnings. (Id. ¶¶ 36–37.) Plaintiffs allege FE2 corroborated FE1’s account 6 of the adverse market conditions. (Id. ¶ 39.) 7 On August 3, 2022, at the start of the Class Period, the Company announced its 8 second quarter financial earnings and revised its sales forecast. (Id. ¶ 41.) Tandem 9 reported second quarter earnings of $200.3 million, which was below analysts’ 10 expectations. (Id.) Plaintiffs allege that the Company noted the Three Headwinds 11 negatively impacted revenue, but the Individual Defendants claimed the Headwinds were 12 not unexpected. (Id.) Tandem also lowered its 2022 Financial Guidance, decreasing 13 estimated sales to the range of $835 million to $845 million, representing a decrease in 14 U.S. sales to $620 million to $625 million, and lowered adjusted EBITDA to 11% of sales. 15 (Id. ¶ 42.) At this news, Tandem’s stock price fell from $68.97 per share on August 3, 16 2022, to $58.60 per share on August 4, 2022, a total decline of $10.37 per share. (Id. ¶¶ 17 42, 45.) 18 In September 2022, Tandem participated in two analyst conferences – the 2022 19 Wells Fargo Healthcare Conference on September 8, 2022, and the Baird 2022 Global 20 Healthcare Conference on September 13, 2022. (Id. ¶ 46.) Plaintiffs allege that during the 21 Wells Fargo Conference, Defendants Sheridan and Vossler represented that the Headwinds 22 the Company experienced during the second quarter had been accounted for in its revised 23 guidance and allegedly stated that August sales had fallen back in line with normal 24 seasonality. (Id. ¶ 47.) In response to this news, between September 7, 2022 and 25 September 13, 2022, Tandem’s stock price increased from $45.65 per share to $56.85 per 26 share. (Id.

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Lowe v. Tandem Diabetes Care, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/lowe-v-tandem-diabetes-care-inc-casd-2024.