Water Island Event-Driven Fund v. MaxLinear, Inc.

CourtDistrict Court, S.D. California
DecidedJuly 15, 2025
Docket3:23-cv-01607
StatusUnknown

This text of Water Island Event-Driven Fund v. MaxLinear, Inc. (Water Island Event-Driven Fund v. MaxLinear, 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
Water Island Event-Driven Fund v. MaxLinear, Inc., (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 WATER ISLAND EVENT-DRIVEN Case No.: 3:23-cv-01607-CAB-VET FUND, on Behalf of Itself and All Others 12 Similarly Situated, et al., ORDER GRANTING MOTIONS TO 13 DISMISS Plaintiffs,

14 v. [Doc. Nos. 75, 77] 15 MAXLINEAR, INC., et al., 16 Defendants. 17

18 On August 28, 2024, the Court dismissed Plaintiffs’ first amended complaint without 19 prejudice. [Doc. No. 61.] On September 18, 2024, Plaintiffs filed a second amended 20 complaint (“SAC”). [Doc. No. 62.] Plaintiffs allege that Defendants made materially false 21 and misleading statements in violation of Sections 10(b) and 20(a) of the Securities 22 Exchange Act. Defendants Silicon Motion Technology Corporation (“SIMO”), CEO 23 Wallace Kou, and CFO Riyadh Lai (“SIMO Defendants”) filed a motion to dismiss the 24 amended complaint. [Doc. No. 75.] Defendants MaxLinear, Inc., CEO Kishore Seendripu, 25 and CFO/CCO Steven Litchfield (“MaxLinear Defendants”) separately filed their own 26 motion to dismiss the amended complaint. [Doc. No. 77.] For the reasons below, the Court 27 GRANTS the motions to dismiss. 28 1 I. BACKGROUND 2 The facts alleged in this amended complaint are nearly identical to the initial 3 complaint. In 2022, Defendant MaxLinear, an American telecommunications corporation, 4 and Defendant SIMO, a Taiwanese chip manufacturer, announced a merger in which 5 MaxLinear would acquire SIMO for $3.8 billion. Lead Plaintiffs are private investment 6 funds who purchased or acquired SIMO American Depository Shares (“ADS”) from May 7 5, 2023 through July 26, 2023 (the “Class Period”). Plaintiffs allege that MaxLinear 8 Defendants committed fraud by assuring ADS investors that the merger was on track to 9 close, only to immediately terminate it after it was approved by China’s main antitrust 10 regulator on July 26, 2023. MaxLinear’s proffered basis for termination was a previously 11 undisclosed, alleged breach of the merger agreement by SIMO over a month prior. 12 As for SIMO Defendants, they allegedly stated that they were proceeding with the 13 merger while omitting that (1) there was a purported breach of the merger agreement that 14 would prevent it from closing and (2) that MaxLinear was not proceeding with basic 15 merger/integration procedures. Additionally, Plaintiffs allege SIMO Defendants had a 16 duty to review MaxLinear’s statements to SIMO investors and update prior statements to 17 disclose the existence of the breach and MaxLinear’s lack of integration planning. 18 II. LEGAL STANDARD 19 Fed. R. Civ. P. 12(b)(6) permits a party to file a motion to dismiss for “failure to 20 state a claim upon which relief can be granted.” “To survive a motion to dismiss, a 21 complaint must contain sufficient factual matter . . . to ‘state a claim to relief that is 22 plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. 23 v. Twombly, 550 U.S. 544, 570 (2007)). 24 “Section 10(b) of the Exchange Act bars conduct involving manipulation or 25 deception, manipulation being practices that are intended to mislead investors by 26 artificially affecting market activity, and deception being misrepresentation, or 27 nondisclosure intended to deceive.” Desai v. Deutsche Bank Sec. Ltd., 573 F.3d 931, 938 28 (9th Cir. 2009) (quoting Ganino v. Citizens Utilities Co., 228 F.3d 154, 161 (2d Cir. 2000)). 1 “Section 20(a) of the Exchange Act imposes secondary liability on controlling persons 2 involved in a primary Section 10(b) violation.” In re: CCIV / Lucid Motors Securities 3 Litigation, 110 F.4th 1181, 1184 (9th Cir. 2024). 4 To assert a claim under Section 10(b), a plaintiff must allege: “(1) a material 5 misrepresentation or omission by the defendant [(‘falsity’)]; (2) scienter; (3) a connection 6 between the misrepresentation or omission and the purchase or sale of a security; (4) 7 reliance upon the misrepresentation or omission; (5) economic loss; and (6) loss causation.” 8 In re NVIDIA Corp. Sec. Litig., 768 F.3d 1046, 1052 (9th Cir. 2014) (citation omitted). 9 Plaintiffs alleging 10(b) violations are subject to heightened pleading standards pursuant 10 to Fed. R. Civ. P. 9(b) and the Private Securities Litigation Reform Act (“PSLRA”). Zucco 11 Partners, LLC v. Digimarc Corp., 552 F.3d 981, 990 (9th Cir. 2009), as amended (Feb. 10, 12 2009). These requirements at the 12(b)(6) stage have been characterized as “formidable.” 13 Metzler Inv. GMBH v. Corinthian Colleges, Inc., 540 F.3d 1049, 1055 (9th Cir. 2008). 14 III. DISCUSSION 15 A. Section 10(b) Claim Against SIMO Defendants 16 Plaintiffs allege that three statements by SIMO were materially false and misleading 17 in violation of Section 10(b). In a May 5, 2023, Form 6-K and press release, SIMO 18 allegedly stated that the merger was “pending satisfaction of customary closing conditions, 19 including antitrust approval [from SAMR].” [SAC ¶ 14.] In a June 28, 2023, Form 6-K, 20 SIMO allegedly stated they had re-filed for antitrust approval in the United States. [SAC 21 ¶ 114.] Finally, in a July 7, 2023 Form 6-K and press release, they stated that they would 22 not conduct an earnings call due to “restrictions associated with the [Merger] Transaction.” 23 [SAC ¶ 173.] 24 Plaintiffs argue that each of these statements were materially false and misleading 25 because they created “the impression that the Merger Agreement was undisputedly in 26 effect, and that the Merger would close if approved by regulators” while omitting the 27 purported facts that (1) SIMO breached the merger agreement as of May 5, 2023, and (2) 28 MaxLinear was not engaging in normal course integration and transition activities, 1 indicating that MaxLinear intended to withdraw from the agreement. [Doc. No. 82 at 12.] 2 Plaintiffs assert these statements “assured investors that the [m]erger would proceed if it 3 was approved by SAMR.” [Id. at 10.] 4 None of SIMO’s alleged statements were necessarily false as the merger did need to 5 satisfy various closing conditions, SIMO had re-filed for U.S. antitrust approval, and SIMO 6 did not conduct an earnings call due to merger restrictions. Indeed, in their opposition, 7 Plaintiffs do not challenge SIMO Defendants’ contention that their statements were not 8 literally false. [Id. at 12.] 9 Nonetheless, SIMO’s statements may still violate Section 10(b) if they omitted 10 material information and were misleading. See Khoja v. Orexigen Therapeutics, Inc., 899 11 F.3d 988, 1008–09 (9th Cir. 2018). An omission “is material if there is a substantial 12 likelihood that the disclosure of the omitted fact would have been viewed by the reasonable 13 investor as having significantly altered the total mix of information made available.” 14 McCormick v. Fund Am. Companies, Inc., 26 F.3d 869, 876 (9th Cir. 1994) (internal 15 quotation marks omitted) (quoting Basic Inc. v. Levinson, 485 U.S. 224, 231–32, (1988)).

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Bluebook (online)
Water Island Event-Driven Fund v. MaxLinear, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/water-island-event-driven-fund-v-maxlinear-inc-casd-2025.