Mehedi v. View, Inc. f/k/a CF Finance Acquisition Corp. II

CourtDistrict Court, N.D. California
DecidedApril 9, 2024
Docket5:21-cv-06374
StatusUnknown

This text of Mehedi v. View, Inc. f/k/a CF Finance Acquisition Corp. II (Mehedi v. View, Inc. f/k/a CF Finance Acquisition Corp. II) 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
Mehedi v. View, Inc. f/k/a CF Finance Acquisition Corp. II, (N.D. Cal. 2024).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 SAN JOSE DIVISION 6 7 ASIF MEHEDI, et al., Case No. 21-cv-06374-BLF

8 Plaintiffs, ORDER GRANTING MOTIONS TO 9 v. DISMISS SECOND AMENDED COMPLAINT 10 VIEW, INC., et al., [Re: ECF No. 181, 183, 184] 11 Defendants.

12 13 This is a putative class action for securities fraud against View, Inc. and various 14 individuals connected to View’s SEC filings. Before the Court are Defendants’ motions to 15 dismiss Plaintiffs’ second amended complaint. ECF No. 181 (“View Mot.”); ECF No. 183 (“CF II 16 Mot.”); ECF No. 184 (“Prakash Mot.”). Plaintiffs oppose the motion. ECF No. 185 (“Opp.”). 17 Defendants have filed replies. ECF Nos. 188 (“Prakash Reply”); ECF No. 189 (“CF II Reply”); 18 ECF No. 190 (“View Reply”). The Court held a hearing on the motions on March 14, 2024. ECF 19 No. 197. 20 For the following reasons, the Court GRANTS the motions to dismiss. 21 I. BACKGROUND 22 View is a technology company that manufactures smart building products, including a 23 “smart” glass panel (“smart panels”) that adjusts in response to the sun. ECF No. 175 (“SAC”) 24 ¶¶ 3, 51. On March 8, 2021, View became a publicly traded company through a merger with 25 CF II, a special purpose acquisition company (“SPAC”). Id. ¶¶ 5, 52, 71. Plaintiffs allege that 26 Defendants made material misrepresentations to investors concerning a materially misstated and 27 understated warranty accrual related to Legacy View’s “smart panels.” See, e.g., id. ¶¶ 87, 92. 1 86; View’s December 23, 2020 De-SPAC Registration Statement, including the two amendments 2 thereto (collectively the “De-SPAC Registration Statement”), id. ¶¶ 88–103; a March 12, 2021 3 Form 8-K, id. ¶¶ 104–11; an April 7, 2021 Form S-1, id. ¶¶ 112–15; a May 12, 2021 press release 4 filed on Form 8-K, id. ¶¶ 116–117; and a May 17, 2021 Form 10-Q, id. ¶¶ 118–27. Plaintiff 5 alleges that the De-SPAC Registration Statement and Proxy were jointly prepared by Legacy 6 View and CF II. Id. ¶ 88. 7 On August 16, 2021, five months after going public, View announced that its Audit 8 Committee “began an independent investigation concerning the adequacy of the company’s 9 previously disclosed warranty accrual” and that View would not file its Form 10-Q for the second 10 fiscal quarter of 2021. SAC ¶ 128. The following day, View’s stock price fell $1.26, or over 11 24%, to close at $3.92. Id. On November 9, 2021, View announced that the Audit Committee 12 “has now substantially completed its independent investigation and has concluded that the 13 Company’s previously reported liabilities associated with all warranty-related obligations and the 14 cost of revenue associated with the recognition of those liabilities were materially misstated.” Id. 15 ¶ 129. View also announced that it would “be restating its previously issued 2019 and 2020 16 annual and certain unaudited interim financial statements and its Q1 2021 and 2020 unaudited 17 interim financial statements.” Id. Finally, View announced that Defendant Vidul Prakash 18 resigned as CFO of View, effective November 8, 2021. Id. The following day on November 10, 19 2021, View’s stock price fell $0.77, or 13.68%, to close at $5.63. Id. ¶ 130. On November 11, 20 2021, View’s stock price fell an additional $0.22, or 3.9%, to close at $5.41. Id. 21 On May 31, 2022, View reported that its yet-to-be restated warranty-related accruals would 22 be $53, $48, and $42 million as of December 31, 2019, 2020, and 2021 respectively. SAC ¶ 132. 23 Ultimately, on June 15, 2022, View filed its December 31, 2021 Form 10-K, setting forth the 24 View’s restated financial information and stating that the SEC was investigating the warranty 25 accrual. Id. ¶¶ 135–37. 26 On August 18, 2021, the initial complaint was filed in this case. See ECF No. 1 27 (“Compl.”). The initial complaint brought claims on behalf of a putative class of investors who 1 losses based on View’s making materially false or misleading statements and failing to disclose 2 material adverse facts about the company’s business, including warranty costs and internal 3 controls. See id. ¶¶ 36–41. On February 8, 2022, the Court appointed Stadium Capital LLC as 4 Lead Plaintiff. ECF No. 67. On July 15, 2022, Stadium Capital filed the first amended complaint. 5 See ECF No. 96 (“FAC”). The first amended complaint extended the end of the class period to 6 May 10, 2022 and asserted 8 claims against View, current and former officers and directors of 7 View and CF II, CF II entities, and PricewaterhouseCoopers LLP. Id. ¶¶ 1, 130–286. On May 2, 8 2023, the Court granted Defendants’ motions to dismiss and dismissed all of Stadium Capital’s 9 claims with leave to amend. See ECF No. 168. On August 21, 2023, Stadium Capital filed the 10 second amended complaint. See SAC. 11 The second amended complaint changes the end of the class period to November 9, 2021 12 and brings claims against: View, Inc. (“View”), f/k/a CF Finance Acquisition Corp. II (“CF II”); 13 current and former officers and directors of View and CF II; and entities related to CF II 14 (collectively “Defendants”). SAC ¶¶ 26–44. The individual View Defendants include: Rao 15 Mulpuri, View’s Chief Executive Officer at all relevant times, and Vidul Prakash, View’s Chief 16 Financial Officer at all relevant times (collectively “View Individual Defendants”). Id. ¶¶ 27–30. 17 The individual CF II Defendants include: Howard Lutnick, CEO and chairman of the board of 18 CF II; Paul Pion, CFO and a director of CF II; Alice Chan, CFO and a director CF II; Anshu Jain, 19 President and a director of CF II; Robert J. Hochberg, a director of CF II; Charlotte S. Blechman, 20 a director CF II (collectively “CF II Individual Defendants”). Id. ¶¶ 31–37. The entity CF II 21 Defendants include: CF Finance Holdings II, LLC (“CF Holdings II,” CF II’s “Sponsor”); Cantor 22 Fitzgerald & Co. (“CF&Co.”, CF II’s advisor); Cantor Fitzgerald, L.P. (“Cantor,” an affiliate of 23 CF II, the Sponsor, and of Cantor, as well as the Sponsor’s sole member); and CF Group 24 Management, Inc. (“CFGM,” Cantor’s managing general partner) (collectively “CF II Entity 25 Defendants” and collectively, with Individual CF II Defendants, “CF II Defendants”). Id. ¶¶ 43– 26 48. 27 Additionally, the second amended complaint adds David Sherman as a named Plaintiff. 1 Claim Section Defendants SAC ¶¶ 2 1 § 14(a); Rule 14a-9 All Defendants 160–98 2 § 20(a) View Individual Defendants and CF II 199–205 3 Defendants 3 § 10(b); Rule 10b-5(b) View and Prakash 256–61 4 8 § 20(a) View Individual Defendants and CF II 262–66 Defendants except Blechman and 5 Hochberg 6 On October 2, 2023, Defendants filed motions to dismiss. There are three separate 7 motions, each brought by a different Defendant or Group of Defendants: (1) a motion to dismiss 8 brought by Defendants View and Mulpuri, see View Mot.; (2) a motion to dismiss brought by 9 Defendant Prakash, see Prakash Mot.; and (3) a motion to dismiss brought by the CF II 10 Defendants, see CF II Mot. The motions are now before the Court. 11 II. LEGAL STANDARD 12 A. Rule 12(b)(6) 13 “A motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to state a 14 claim upon which relief can be granted ‘tests the legal sufficiency of a claim.’” Conservation 15 Force v. Salazar, 646 F.3d 1240, 1241–42 (9th Cir. 2011) (quoting Navarro v. Block, 250 F.3d 16 729, 732 (9th Cir. 2001)). When determining whether a claim has been stated, the Court accepts 17 as true all well-pled factual allegations and construes them in the light most favorable to the 18 plaintiff. Reese v. BP Expl. (Alaska) Inc., 643 F.3d 681, 690 (9th Cir. 2011).

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Mehedi v. View, Inc. f/k/a CF Finance Acquisition Corp. II, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mehedi-v-view-inc-fka-cf-finance-acquisition-corp-ii-cand-2024.