Oklahoma Firefighters Pension and Retirement System v. Fortinet, Inc., et al.; State of Rhode Island Office of the General Treasurer on Behalf of the Employees’ Retirement System of the State of Rhode Island v. Fortinet, Inc., et al.

District Court, N.D. California·Decided February 20, 2026·No. 3:25-cv-08037·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 OKLAHOMA FIREFIGHTERS PENSION Case No. 25-cv-08037-AMO AND RETIREMENT SYSTEM, 8 Plaintiff, ORDER RE MOTIONS TO 9 CONSOLIDATE, APPOINT LEAD v. PLAINTIFF, AND APPOINT LEAD 10 COUNSEL FORTINET, INC., et al., 11 Re: Dkt. Nos. 23, 31, 42 Defendants. 12 STATE OF RHODE ISLAND OFFICE OF THE GENERAL TREASURER ON Case No. 25-cv-08888-AMO 13 BEHALF OF THE EMPLOYEES’ RETIREMENT SYSTEM OF THE STATE Re: Dkt. No. 21 14 OF RHODE ISLAND, 15 Plaintiff, 16 v.

17 FORTINET, INC., et al., 18 Defendants.

19 20 Pending before the Court are three putative class members’ motions requesting 21 consolidation, appointment of lead plaintiff, and appointment of lead counsel pursuant to the 22 Private Securities Litigation Reform Act of 1995 (“PSLRA”). The matters are fully briefed and 23 suitable for decision without oral argument. Accordingly, the hearings set for March 5, 2026, are 24 VACATED. See Civil L.R. 7-6; Fed. R. Civ. Pro. 78(b). Having read the parties’ papers and 25 carefully considered their arguments and the relevant legal authority, and good cause appearing, 26 the Court CONSOLIDATES the above-captioned cases, APPOINTS Union Asset Management 27 Holding AG as lead plaintiff, and APPOINTS Bernstein Litowitz Berger & Grossman LLP as 1 I. CONSOLIDATION 2 The PSLRA instructs that before appointing a lead plaintiff, the Court first must consider 3 any motions to consolidate actions that assert “substantially the same claim or claims.” 15 U.S.C. 4 § 78u-4(a)(3)(B)(ii). Under Federal Rule of Civil Procedure 42(a), the Court may consolidate 5 actions that “involve a common question of law or fact.” District courts have “broad discretion” 6 to consolidate actions under Rule 42(a). Shenwick v. Twitter, Inc., No. 16-cv-05314-JST, 2016 7 WL 10672428, at *1 (N.D. Cal. Dec. 22, 2016) (quoting Investors Research Co. v. Dist. Court, 8 877 F.2d 777, 777 (9th Cir. 1989)). Courts have found that securities class actions brought under 9 the PSLRA “are particularly well suited to consolidation pursuant to Rule 42(a).” Hessefort v. 10 Super Micro Computer, Inc., 317 F. Supp. 3d 1056, 1060 (N.D. Cal. 2018) (quoting Miami Police 11 Relief & Pension Fund v. Fusion-io, Inc., No. 13-cv-05368-LHK, 2014 WL 2604991, at *3 (N.D. 12 Cal. June 10, 2014)). 13 All three motions before the Court seek to consolidate the above-captioned actions. See 14 Oklahoma Firefighters, Dkt. Nos. 23, 31, 42; Rhode Island, Dkt. No. 21.1 Both are putative class 15 actions brought on behalf of persons or entities that purchased Fortinet, Inc. (“Fortinet”) common 16 stock between November 8, 2024, and August 6, 2025. Oklahoma Firefighters, Dkt. No. 1 ¶ 1; 17 Rhode Island, Dkt. No. 1 ¶ 1. Both actions allege identical claims against Fortinet, including 18 violations of Sections 20(a), 10(b), and Rule 10b-5 of the Exchange Act. Id. Because the cases 19 assert substantially the same PSLRA claims and involve similar questions of law and fact, the 20 Court CONSOLIDATES the above-captioned cases. 21 II. APPOINTMENT OF LEAD PLAINTIFF 22 The Court next takes up the motions to appoint lead plaintiff. The Ninth Circuit instructs 23 district courts to follow a three-step process for determining appointment of lead plaintiff in 24 private securities actions arising under the PSLRA. See In re Cavanaugh, 306 F.3d 726, 729-730 25 (9th Cir. 2002); Xu v. FibroGen, Inc., No. 21-cv-02623-EMC, 2021 WL 3861454, at *3 (N.D. Cal. 26 Aug. 30, 2021). First, a plaintiff must satisfy the PSLRA’s notice requirement by publishing 27 1 notice “in a widely circulated national business-oriented publication or wire service” advising 2 members of the putative class of the pending action within 20 days of filing the complaint. 15 3 U.S.C. § 78u-4(3)(A)(i). Second, the Court must appoint the plaintiff “most capable of adequately 4 representing the interests of class members.” 15 U.S.C. § 78u-4(3)(B)(i). There is a rebuttable 5 presumption that the “most adequate plaintiff” is the person who (1) filed the complaint or made a 6 motion in response to the notice; (2) has the largest financial interest; and (3) otherwise satisfies 7 Federal Rule of Civil Procedure 23. 15 U.S.C. § 78u-4(a)(3)(B)(iii)(I); see Cavanaugh, 306 F.3d 8 at 729-30 (describing the PSLRA process for appointing lead plaintiff). Third and finally, the 9 Court must consider any contentions by the putative class members to rebut the presumption that 10 the most adequate plaintiff will satisfy Rule 23(a)’s typicality and adequacy requirements. 15 11 U.S.C. § 78u-4(a)(3)(B)(iii)(II). 12 The Court first examines whether the notice requirement was satisfied. On September 22, 13 2025, Oklahoma Firefighters Pension and Retirement System (“Oklahoma Firefighters”) filed the 14 first of these cases. Oklahoma Firefighters, Dkt. No. 1. The same day, counsel for Oklahoma 15 Firefighters published a notice on ACCESS Newswire, alerting investors of the action and 16 informing them of the 60-day deadline to seek appointment as lead plaintiff. Oklahoma 17 Firefighters, Dkt. No. 7-1. Union Asset Management Holding AG (“Union”) filed its motion for 18 appointment of lead plaintiff on November 21, 2025. Oklahoma Firefighters, Dkt. No. 42. Thus, 19 the notice requirement is satisfied because the notice was published within 20 days of 20 the Oklahoma Firefighters complaint’s filing and because Union filed its motion to be appointed 21 lead plaintiff within 60 days of the notice’s publication. 22 Next, the Court considers whether Union is the most capable plaintiff to adequately 23 represent the interest of the class members. See 15 U.S.C. § 78u-4(a)(3)(B)(i)-(iii). As noted 24 above, the most capable plaintiff “is the one who has the greatest financial stake in the outcome of 25 the case.” Cavanaugh, 306 F.3d at 730. District courts often consider four factors in evaluating a 26 plaintiff’s financial stake, including the total number of shares and net shares purchased during the 27 class period, total net funds expended during the class period, and the approximate losses during 1 WL 4933611, at *3 (N.D. Cal. Oct. 7, 2019) (quoting In re Olsten Corp. Sec. Litig., 3 F. Supp. 2d 2 286, 295 (E.D.N.Y. 1998)). Here, Union alleges purchasing more than 2.1 million shares of 3 Fortinet common stock and incurring a total loss of over $75.5 million. Oklahoma Firefighters, 4 Dkt. No. 42 at 11-12. No movant contests that Union has the largest financial interest at stake, see 5 Oklahoma Firefighters, Dkt. Nos. 53, 54, and thus, the Court finds that Union has the largest 6 financial interest at stake. 7 Finally, the Court examines whether Union satisfies the Rule 23 typicality and adequacy 8 requirements. See 15 U.S.C. § 78u-4(a)(3)(B)(iii)(I).

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Oklahoma Firefighters Pension and Retirement System v. Fortinet, Inc., et al.; State of Rhode Island Office of the General Treasurer on Behalf of the Employees’ Retirement System of the State of Rhode Island v. Fortinet, Inc., et al., (N.D. Cal. 2026).

Oklahoma Firefighters Pension and Retirement System v. Fortinet, Inc., et al.; State of Rhode Island Office of the General Treasurer on Behalf of the Employees’ Retirement System of the State of Rhode Island v. Fortinet, Inc., et al. (Oklahoma Firefighters Pension and Retirement System v. Fortinet, Inc., et al.; State of Rhode Island Office of the General Treasurer on Behalf of the Employees’ Retirement System of the State of Rhode Island v. Fortinet, Inc., et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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