PSLRA
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The Private Securities Litigation Reform Act of 1995 (PSLRA) changed the pleading standards for securities fraud cases. Prior to the PSLRA, the sufficiency of a complaint for securities fraud was governed not by Rule 8, but by the heightened pleading standard set forth in Rule 9(b). See Greenstone v. Cambex Corp., 975 F.2d 22, 25 (1st Cir. 1992) (Breyer, J.) (collecting cases).
Tellabs, Inc. v. Makor Issues and Rights, Ltd., 127 S. Ct. 2499 (2007) interpreted and imposed new pleading requirements under the PSLRA.