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HomeMy WebLinkAboutAgenda Fire Pension 071017 PALM BEACH GARDENS FIREFIGHTERS’ PENSION FUND Meeting of Monday July 10, 2017 Location: City Hall, Council Chambers Palm Beach Gardens City Hall 10500 North Military Trail Palm Beach Gardens, FL 33410 Time: 1 PM AGENDA 1. Call Meeting to Order 2. Public Comments 3. Minutes: • Regular Meeting Held on May 3, 2017 4. ICMA – Steve Feigilis 5. Investment Monitor Report: AndCo Consulting (Dan Johnson) 6. Attorney Report: Sugarman & Susskind, P.A. (Pedro Herrera) • BanCorpSouth, Inc. Litigation Memo • Legislative Update & Action Plan Memo 7. Administrative Report: Resource Centers (Audrey Ross) • Disbursements • Benefit Approvals • Financial Statements 8. Old Business • KTMC Brochure 9. New Business 10. Next Meeting Previously Scheduled Wednesday August 2, 2017 at 1PM 11. Adjourn PLEASE NOTE: Should any interested party seek to appeal any decision made by the Board with respect to any matter considered at such meeting or hearing, he will need a record of the proceedings, and for such purpose he may need to insure that a verbatim record of the proceedings is made, which record includes the testimony and evidence upon which the appeal is to be based. In accordance with the Americans With Disabilities Act of 1990, persons needing a special accommodation to participate in this meeting should contact The Resource Centers, LLC no later than four days prior to the meeting. THE RESOURCE CENTERS , LLC 4360 Northlake Boulevard, Suite 206 Palm Beach Gardens, FL 33410 Phone (561) 624-3277 Fax (561) 624-3278 WWW.RESOURCECENTERS.COM UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION WILLIAM E. BURGES, et al., ) ) Plaintiffs ) v. ) NO. 3:14-cv-1564 ) CHIEF JUDGE CRENSHAW BANCORPSOUTH, INC., et al., ) ) Defendants ) MEMORANDUM OPINION Pending before the Court, for the second time, is a Motion to Certify the Class (Doc. No. 97), filed by Palm Beach Gardens Firefighters Pension Fund (“the Fund”).1 On April 28, 2016, this Court entered an Order granting the Fund’s Motion to Certify the Class (Doc. Nos. 157-58.) The Sixth Circuit Court of Appeals vacated that Order and remanded the case to this Court for further proceedings. (Doc. No. 178.) The parties have agreed, since that remand, that all discovery necessary to the determination of class certification is completed and no further briefing on class certification is necessary. (Doc. No. 197.) The Magistrate Judge has ordered a stay of merits discovery pending resolution of the class certification motion. (Id.) INTRODUCTION In this federal securities fraud action, the Plaintiffs allege that Bancorpsouth, Inc. (“the Bank”) and its Chief Executive Officer (James Rollins), its Chief Operating Officer and President 1 The Court appointed Palm Beach Gardens Firefighters Pension Fund to be Lead Plaintiff in this action on October 22, 2014. (Doc. No. 31.) It found that the Fund, which possesses the largest financial interest in the relief sought by the class, would fairly and adequately represent the interests of the class. 15 U.S.C. § 78u-4(a)(3)(B). Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 1 of 22 PageID #: 6577 (James Kelley), and its Chief Financial Officer (William Prater) (collectively, “Defendants”) made materially false and misleading statements and omissions regarding the Bank’s compliance with federal laws and that those statements and omissions violated the Securities Exchange Act of 1934 and Rule 10b-5 promulgated thereunder. The Amended Complaint (Doc. No. 39) alleges that Defendants made false, misleading statements and omissions regarding (1) the Bank’s compliance with critical anti-money laundering and Bank Secrecy Act regulations as well as the Bank’s fair lending practices and (2) the closing of two pending mergers/acquisitions. Plaintiffs allege that Defendants knew the Bank was not in compliance with the anti-money laundering and Bank Secrecy Act regulations, and yet they affirmatively stated that (1) they were in compliance with all banking laws and regulations, (2) they expected the two planned mergers to close in the second quarter of 2014, and (3) they expected to receive regulatory approval for those mergers.2 (Doc. No. 39, ¶¶ 108- 155.) The Fund seeks to bring this action on behalf of all persons who purchased or otherwise acquired the common stock of the Bank from January 8, 2014, through July 21, 2014, and it asks the Court to certify a class of those persons pursuant to Fed. R. Civ. P. 23. Defendants maintain that the Fund has not met the requirements of Rule 23. 2 On July 10, 2015, this Court dismissed the alleged misrepresentations that were “forward looking” statements concerning the timing and the expected regulatory approvals of the two mergers at issue. (Doc. Nos. 72-73.) Federal securities law includes a “safe harbor” which excuses liability for statements containing projections of revenues, income, earnings or other financial items; statements of plans and objectives of management for future operations; and statements of future economic performance. 15 U.S.C. § 78u-5. The Court dismissed the forward-looking statements concerning what Defendants anticipated and/or expected to happen concerning the two mergers, finding they were protected by the Safe Harbor and were not false or misleading. (Doc. Nos. 72-73.) 2 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 2 of 22 PageID #: 6578 In vacating this Court’s prior Order certifying a class, the Sixth Circuit stated that this Court (1) did not set forth the standard requiring it to “rigorously analyze” Plaintiffs’ claims before certifying the action as a class action, (2) did not address the bulk of Rule 23's requirements in its Order, and (3) did not define the class it certified. (Doc. No. 178.) The Court will address those concerns and further expand on why it is appropriate to grant Plaintiffs’ Motion. The Court adopts its prior Order granting the Motion to Certify the Class (Doc. No. 158) that specifically defines the class as: All persons who purchased or otherwise acquired the publicly traded common stock of BancorpSouth, Inc. between February 12, 2014 and July 21, 2014, inclusive, and who were damaged thereby. Excluded from the Class are Defendants, the officers and directors of the Company at all relevant times, members of their immediate families and their legal representatives, heirs, successors or assigns and any entity in which Defendants have or had a controlling interest. (Doc. No. 158 at 2.) CLASS CERTIFICATION In order to certify a class, the Court must be satisfied that the Fund has met the requirements of both Rule 23(a) and Rule 23(b) of the Federal Rules of Civil Procedure.3 A class action will be certified only if, after rigorous analysis, the Court is satisfied that the prerequisites of Rule 23(a) have been met and also that the action falls within one of the categories under Rule 23(b). Castillo v. Envoy Corp., 206 F.R.D. 464, 467-68 (M.D. Tenn. 2002). The decision whether to certify a class is committed to the sound, broad discretion of the district judge and turns on the particular facts and circumstances of each individual case. In re Whirlpool Corp. Front-Loading Washers Product Liability Litigation, 722 F.3d 838, 850 (6th Cir. 2013); Ballan v. Upjohn Co., 159 F.R.D. 473, 479 3 As the Sixth Circuit noted, in contesting certification, Defendants challenged only some of Plaintiffs’ allegations. (Doc. No. 178 at 3.) 3 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 3 of 22 PageID #: 6579 (W.D. Mich. 1994). The party seeking class certification bears the burden of showing that the requirements for class certification are met. Bridging Communities Inc. v. Top Flite Financial Inc., 843 F.3d 1119, 1124 (6th Cir. 2016). RULE 23(a) Rule 23(a) establishes four requirements for class certification: the class is so numerous that joinder of all members is impracticable; there are questions of law or fact common to the class; the claims or defenses of the representative party are typical of those of the class; and the representative party will fairly and adequately protect the interests of the class. Fed. R. Civ. P. 23(a). Numerosity Rule 23 (a)(1) requires that the proposed class be so numerous that joinder of all members is impracticable. While there is no strict numerical test, “substantial” numbers usually satisfy the numerosity requirement. In re Polyurethane Foam Antitrust Litigation, 314 F.R.D. 226, 237 (N.D. Ohio 2014) (citing Daffin v. Ford Motor Co., 458 F.3d 549, 552 (6th Cir. 2006)). Numerosity is generally assumed to have been met in class action suits involving nationally traded securities. In re Direct General Corp. Securities Litigation, 2006 WL 2265472 at * 2 (M.D. Tenn. Aug. 8, 2006); Ross v. Abercrombie & Fitch Co., 257 F.R.D. 435, 442 (S. D. Ohio 2009). The Fund has adequately shown that the Bank’s common stock is nationally traded, with more than 200 large institutional investors, and that there are most likely thousands of class members. (Doc. No. 98 at 8.) The Court finds that the numerosity requirement has been met in this case and that Defendants do not suggest otherwise. (Doc. No. 115.) 4 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 4 of 22 PageID #: 6580 Commonality Rule 23's second requirement for class certification is that there be questions of law or fact common to the class. Fed. R. Civ. P. 23(a)(2). To demonstrate commonality, the Fund must show that class members have suffered the same injury. Wal-Mart Stores, Inc. v. Dukes, 131 S.Ct. 2541, 2555 (2011); Whirlpool, 722 F.3d at 851. Their claims must depend upon a common contention of such a nature that it is capable of class-wide resolution, which means that determination of its truth or falsity will resolve an issue that is central to the validity of each claim in one stroke. Id.; Wal- Mart, 131 S.Ct. at 2551. What matters to class certification is not the raising of common questions, but the capacity of a class-wide proceeding to generate common answers apt to drive the resolution of the litigation. Wal-Mart, 131 S.Ct. at 2551. The mere fact that questions peculiar to each individual member of the class remain after the common questions of the defendant’s liability have been resolved does not dictate the conclusion that a class action is impermissible. In re American Medical Systems, Inc., 75 F.3d 1069, 1080 (6th Cir. 1996); see also Young v. Nationwide Ins. Co., 693 F.3d 532, 543 (6th Cir. 2012) (presence of questions peculiar to each individual member of the class was no bar when liability arose from a single course of conduct). The Fund asserts that common questions in this case include: (1) whether Defendants’ alleged statements and omissions were materially false or misleading; (2) whether federal law was violated by Defendants’ alleged acts; and (3) to what extent class members have sustained damages. Defendants contest commonality based on the lack of reliance. The Court will address reliance and the Fund’s reliance upon the “fraud-on-the-market presumption” in the discussion concerning Rule 23(b)(3) and predominance. See Halliburton Co. v. Erica P. John Fund, Inc., 134 5 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 5 of 22 PageID #: 6581 S.Ct. 2398, 2404 (2014) (elements of the presumption have everything to do with the issue of predominance under Rule 23(b)(3)). In summary, as it relates to commonality, application of the “fraud-on-the-market presumption” allows the Court to presume that class members relied upon the alleged misstatements such that the question of liability is not an individualized issue. The first two common questions posed by the Fund – whether the alleged misstatements and omissions are materially false or misleading and whether Defendants’ alleged acts violated federal law – do arise from a single course of conduct by Defendants. The alleged misstatements and omissions were the same as relates to all potential class members. Determination of their truth or falsity will resolve an issue that is central to the validity of each of the claims in one stroke. In re Whirlpool, 722 F.3d at 852. If those misstatements and omissions violated federal law, they violated federal law as to all potential class members. Therefore, answering those questions will generate common, class-wide answers concerning liability. The Court finds that the commonality requirement is satisfied. Typicality and Adequacy Rule 23(a)(3) requires the Fund to show that its claims are typical of the claims of the proposed class. A plaintiff’s claim is typical if it arises from the same event, practice, or course of conduct that gives rise to the claims of other class members and if its claims are based on the same legal theory. American Medical Systems, 75 F.3d at 1082. The Fund’s interests must be aligned with those of the putative class and, in pursuing its own claims, the Fund must also advance the interests of the class members. Id. Rule 23(a)(4) requires the Court to find that the Fund will fairly and adequately protect the interests of the class. In order to satisfy the requirement of adequacy, the class representative must 6 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 6 of 22 PageID #: 6582 be part of the class and possess the same interest and suffer the same injury as the class members. Young, 693 F.3d at 543. In other words, the Fund must have common interests with unnamed members of the class and must be able to rigorously prosecute the interests of the class through qualified counsel. The Fund has carried its burden of establishing that its claims are the same as those of the class. The Fund and the class both allege that Defendants violated Sections 10(b) and 20(a) of the Securities Exchange Act and Rule10b-5 by making statements that misrepresented or omitted material facts. The claims of the Fund and the class involve the same security (BancorpSouth), the same alleged misstatements and omissions, the same legal theories, and the same evidence. Whether those allegations are true or not will be the same for the Fund as for the proposed class members. Defendants argue that because the Fund failed to file the mandatory Reform Act Certification with its Amended Complaint (Doc. No. 39), it does not meet the typicality and adequacy requirements of Rule 23(a). Federal law provides that each plaintiff seeking to serve as a representative party on behalf of a class shall provide a sworn certificate with the complaint. 15 U.S.C. § 78u-4(a)(2)(A). The Fund filed a certification with its Motion for Appointment as Lead Plaintiff (Doc. No. 19-2) but not with its Amended Complaint. A class representative need not file a new certification each time the complaint is amended. Thorpe v. Walter Investment Mgmt. Corp., 2016 WL 4006661 at * 10 (S.D. Fla. March 16, 2016); Atlas Air Worldwide Holdings, Inc. Sec. Litig., 324 F.Supp.2d 474, 500 (S.D. N.Y. 2004) (“[W]e think such a requirement would be a useless burden”). The Court finds nothing improper about the Fund’s certification in this litigation and Defendants have shown no prejudice because of the certification. The certification submitted by the Fund with its earlier motion is sufficient. 7 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 7 of 22 PageID #: 6583 Defendants next argue that the Fund cannot adequately represent the class because of its lack of meaningful involvement in and understanding of its “lawyer-driven” litigation. Defendants contend that the Fund did not become a Plaintiff in this case on its own, but rather, Plaintiffs’ counsel brought the case to the Fund’s attention pursuant to a portfolio monitoring agreement between counsel and the Fund.2 Defendants point out that some courts have criticized such agreements as raising conflicts of interest. For example, in Iron Workers Local No. 25 Pension Fund v. Credit-Based Asset Servicing and Securitization, LLC, 616 F.Supp 2d 461, 464 (S.D. N.Y. 2009), the court held that the pension fund was in no position adequately to monitor the conduct of the litigation based, in part, on its monitoring agreement with counsel. In that monitoring agreement, the attorneys provided free monitoring of the pension fund’s investments in exchange for the pension fund’s agreement that, if the attorneys recommended bringing a securities class action, the pension fund would retain those same attorneys, on a contingency fee basis, to represent it in that action. Id. Defendants have not alleged such a provision in this case.3 On the other hand, the Fund relies on cases in which the courts have recognized the importance of such monitoring agreements and held that they present no bar to class certification. See, e.g., Willis v. Big Lots, Inc., __ F. Supp. 3d __, 2017 WL 1063479 at * 10 (S.D. Ohio March 17, 2017) (fact that plaintiff learned of case through monitoring agreement did not render plaintiff 2 Under such monitoring agreements, a law firm overlooks the specific fund and recommends to its administrators when the law firm believes a violation of the securities laws has occurred. Plumbers & Pipefitters Nat. Pension Fund v. Burns, 292 F.R.D. 515, 523 (N.D. Ohio 2013). 3 The Chairman of the Fund and representative designated by the Fund to testify in deposition, Richard Rhodes, testified that the Fund could have considered other counsel. (Doc. No. 118-3 at 63.) 8 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 8 of 22 PageID #: 6584 inadequate to serve as class representative); Plumbers & Pipefitters Nat. Pension Fund v. Burns, 292 F.R.D. 515, 523 (N.D. Ohio 2013) (citing United Food & Commercial Workers Union v. Chesapeake Energy Corp., 281 F.R.D. 641, 655 (W.D. Okla. 2012)). In Plumbers, the court found that the fund was under no obligation to retain the law firm to pursue its claims identified through the monitoring agreement and, noting that other courts routinely reject attacks on the propriety of portfolio monitoring agreements, held that the monitoring agreement did not create a conflict or render the plaintiff inadequate to represent the class. Plumbers, 292 F.R.D. at 523. The court stated that at least one other court has held that such a monitoring agreement might actually favor adequacy of the counsel retained to monitor a fund because the firm’s ongoing relationship with the fund would depend on its performance in the litigation. Id. Similarly, in United Food, the court concluded that the monitoring agreement did not present a conflict of interest impacting the adequacy of the lead plaintiff’s representation. United Food, 281 F.R.D. at 654-655. The court said that some courts have found that monitoring agreements actually illustrate a lead plaintiff’s involvement in and awareness of the financial issues involved in the litigation. Id. The Court finds that the monitoring agreement between the Fund and counsel in this case, which does not require the Fund to hire specific counsel for this purpose, does not render the Fund inadequate to be the class representative in this case. The agreement does not create a conflict of interest, impair the Fund’s exercise of independent judgment, and most of all, does not render the Fund substantially different from other members of the class. Defendants also contend that the Fund has ceded control of this litigation to counsel. According to Defendants, this fact is shown because the Fund’s representative, Mr. Rhodes, knew 9 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 9 of 22 PageID #: 6585 very little about the litigation. Both Defendants and the Fund cite excerpts from the testimony of Mr. Rhodes to support what he did and did not know about the litigation.4 The Court has reviewed the deposition of Mr. Rhodes (Doc. No. 118-3) and finds the Fund representative’s understanding of the litigation and commitment to it is adequate. It does not preclude the Fund from being Lead Plaintiff in this case. Mr. Rhodes explained the allegations underlying this litigation and the specific misrepresentations allegedly made – that in connection with buying two banks, BancorpSouth made statements that they were in compliance with all the rules and regulations of banking when they were not. (Doc. No. 118-3 at 67.) He also explained why the Fund was asked to serve as lead plaintiff – because it was the largest client and had the largest loss. (Id.) As noted above, Mr. Rhodes understood that the Fund’s role was to act as a fiduciary of the class and to maximize the recovery for the class and that the Fund would be required to answer depositions, provide records and hire counsel. (Doc. 118-3 at 71.) This understanding of the basic facts underlying the claims, some general knowledge, and a willingness and ability to participate in discovery are sufficient to meet the adequacy requirement of Rule 23(a)(4). Plumbers, 292 F.R.D. at 520. Defendants assert two additional arguments that the Fund is not typical or adequate in this case. First, Defendants argue that the Fund is represented by outside counsel, the Sugarman firm, which will be able to participate in a share of any class recovery without Court approval. Any 4 For example, Defendants point out that Mr. Rhodes testified that the Fund would be required to answer depositions, provide records and hire counsel. (Doc. 118-3 at 71.) But just before that, he also testified that the Fund’s role was to act as a fiduciary of the class and to maximize the recovery for the class. (Id.) 10 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 10 of 22 PageID #: 6586 attorneys’ fee awards in this matter, however, will be determined by the Court, so they will not be without court approval. In addition, the Sugarman firm is the Fund’s regular outside counsel and represents the Fund, not the class. The Robbins Geller firm represents the class. The fact that both firms may eventually recover their fees out of the same settlement or judgment does not change their ethical or professional duties to their clients and to the proposed class. Plumbers, 292 F.R.D. at 523, n. 11. Furthermore, representation by the outside law firm will ensure that the Fund will fulfill its duty adequately to monitor class counsel. Id. at 523. Second, Defendants claim that Plaintiffs’ case depends in significant part on the testimony of a third party, David Michael Stamm, who was the Senior Vice-President Portfolio Manager of Dana Investment Advisors, the Fund’s outside investment manager. Defendants contend that Mr. Stamm has a view of the facts that clashes with important allegations of the Amended Complaint.5 If that is true, then Defendants will be able to challenge that testimony at trial, but it does not show that the Fund is not adequate or typical to represent the class. Defendants have not shown that statements of Mr. Stamm are binding on the Fund. For all these reasons, the Court finds that the Fund has shown sufficient typicality and adequacy and meets the requirements of Fed. R. Civ. P. 23(a). 5 Mr. Stamm testified that the corrective disclosures in this case did not correct any “misunderstanding” he had about BancorpSouth. (Doc. No. 116 at 122.) The Amended Complaint alleges that the corrective disclosures “shocked investors.” (Doc. No. 39 at 34.) 11 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 11 of 22 PageID #: 6587 Rule 23(b) As indicated above, if a plaintiff satisfies the requirements of Rule 23(a), then the Court looks to whether the proposed class action falls into any of the categories under Rule 23(b). Plaintiffs claim that their action satisfies the requirements of Rule 23(b)(3). Under that subsection, Plaintiffs must show that common questions of law or fact predominate over any questions affecting only individual members and that a class action is superior to other available methods for fairly and efficiently adjudicating the controversy. Fed. R. Civ. P. 23(b)(3). Plaintiffs assert that, as with their arguments concerning commonality, common questions of law and fact predominate in this case and the claims of all class members will be proved by the same evidence. To recover damages for securities violations, the Fund must prove (1) a material misleading statement or omission by Defendants, (2) scienter, (3) a connection between the misrepresentation or omission and the purchase or sale of a security, (4) reliance upon the misrepresentation or omission, (5) economic loss, and (6) loss causation. Halliburton, 134 S.Ct. at 2407. Class members will be required to prove the same elements. Defendants argue that Plaintiffs cannot show that common issues of fact or law predominate over individual issues here because there are individual issues concerning reliance. In order to recover damages in a private securities action such as this one, Plaintiffs must prove that they relied on Defendants’ misrepresentations. Halliburton , 134 S.Ct. at 2405. Defendants argue that Plaintiffs’ reliance is a predominant, but not common, issue in this case because each Plaintiff’s reliance or lack thereof is an individual issue. Plaintiffs contend that, with regard to the alleged misrepresentations, they can show reliance by means of the fraud-on-the-market presumption. 12 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 12 of 22 PageID #: 6588 Fraud-On-The-Market Presumption The Supreme Court has found that investors may satisfy the reliance requirement by invoking a presumption known as the “fraud-on-the-market presumption.” Halliburton, 134 S.Ct. at 2411-15; Basic Inc. v. Levinson, 108 S.Ct. 978, 989-90 (1988). Without the presumption of reliance, a Rule 10b-5 suit cannot proceed as a class action because each plaintiff would have to prove reliance individually, so common issues would never predominate over individual ones as required by Rule 23(b)(3). Halliburton at 2416. The fraud-on-the-market theory is based on the hypothesis that, in an open and developed securities market, the price of a company’s stock is determined by the available material information regarding the company and its business. Basic, 108 S.Ct. at 989; Wilkof v. Caraco Pharmaceutical Laboratories, Ltd., 280 F.R.D. 332, 342 (E.D. Mich. 2012). Misleading statements will therefore defraud purchasers of stock even if the purchasers do not directly rely on the misstatements because the market price of the stock was adversely affected by the misrepresentation. Id. To demonstrate that the fraud-on-the-market presumption of reliance applies, a plaintiff must show that (1) the alleged misrepresentations were publicly known, (2) they were material, (3) the stock traded in an efficient market, and (4) the plaintiff traded the stock between the time the misrepresentations were made and when the truth was revealed.6 Halliburton, 134 S.Ct. at 2408. The theory is based on the premise that certain well-developed markets are efficient processors of public information. Amgen Inc. v. Conn. Retirement Plans and Trust Funds, 133 S.Ct. 1184, 1192 (2013). If a market is generally efficient in incorporating publicly available information into a security’s 6 Plaintiffs have in fact alleged that they and the proposed class members traded the stock between the time the misrepresentations were made and the time when the truth was revealed. (Doc. No. 39 at 60.) The Defendants do not dispute that allegation. 13 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 13 of 22 PageID #: 6589 market price, it is reasonable to presume that a particular public, material misrepresentation will be reflected in the security’s price. Id. The presumption can be rebutted by appropriate evidence, such as proof that news of the truth entered the market and dissipated the effects of the prior misstatements. Amgen, 133 S.Ct. at1193 and 1204. Any showing that severs the link between the alleged misrepresentation and either the price received or paid by the plaintiff or his decision to trade at a fair market price will be sufficient to rebut the presumption. Halliburton,134 S.Ct. at 2408. For example, evidence that a plaintiff knew the company’s statements were false but sold his shares nevertheless could rebut the presumption of reliance. Basic, 485 U.S. at 248. a) Publicly Known Defendants argue that Plaintiffs cannot show that the misrepresentations at issue were publicly known.7 If the misrepresentation was not publicly known, then it could not have distorted the stock’s market price. Halliburton, 134 S.Ct. at 2413. Defendants assert that showing the alleged misrepresentations are in the public domain falls short of proof that they are “publicly known” as required for the presumption to apply. Defendants contend that the Fund must at least demonstrate that a critical mass of analysts, market makers or other market actors knew of the alleged misrepresentations and wrote about them or took some other action that would tend to affect the stock price. (Doc. No. 115 at 2.) Requiring Plaintiffs to show that certain people read and relied on 7 A market may more readily process certain forms of widely disseminated and easily digestible information, such as public merger announcements, than information more difficult to acquire and understand, such as obscure technical data buried in a filing with the SEC. Amgen, 133 S.Ct. at 1197, n. 6. The information in the merger agreements here, however, was not obscure technical data or buried. It was information filed publicly with the SEC in which BancorpSouth represented that it was in compliance with all applicable laws, statutes, and regulations. 14 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 14 of 22 PageID #: 6590 the alleged misrepresentations, however, would circumvent the presumption by requiring Plaintiffs to show reliance. The misrepresentations at issue herein were found in Registration Statements, Proxy Statements, and Merger Agreements, public documents that were filed with the Securities and Exchange Commission (“SEC”). For example, the Bank’s February 28, 2014 Registration Statement included, as Annex A, an Agreement and Plan of Reorganization in which BancorpSouth allegedly misrepresented that it was in compliance with all applicable laws, statutes, and regulations. (Doc. No. 39 at ¶ 127.) Other courts have summarily recognized that SEC filings are sufficiently public to be “publicly known.” See, e.g., In re Neustar, Inc. Securities Litigation, 2015 WL 5674798 at * 7 (E.D. Va. Sept. 23, 2015) and In re Red Hat, Inc. Securities Litigation, 261 F.R.D. 83, 91 (E.D. N.C. 2009). The Court agrees with these cases and finds that the merger agreements filed with the SEC in this case are sufficiently public to satisfy the Fund’s obligation under the first element of the presumption for purposes of class certification. b) Materiality Even though materiality is an element for invoking the fraud-on-the-market presumption, the Supreme Court has held that it should be left to the merits stage of the litigation because it does not bear on the predominance requirement of Rule 23(b)(3). Halliburton at 2416. In Amgen, the Court stated that proof of materiality is not a prerequisite to class certification, noting that materiality is a common question and the class will either prevail or fall in unison as to that issue. Amgen, 133 S.Ct. at 1191.8 Thus, the Court need not address materiality on this motion.9 8 Similarly, the Supreme Court has held that loss causation need not be proved at the class 15 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 15 of 22 PageID #: 6591 c) Efficient Market As noted above, the fraud-on-the-market theory rests on the premise that certain well- developed markets are efficient processors of public information. Amgen, 133 S.Ct. at 1192. In such markets, the market price of shares will reflect all publicly available information. Id. Here, the Fund asserts that because the stock was widely traded on the New York Stock Exchange (“NYSE”), the market is efficient. Defendants contend that the Fund has not carried its burden to prove an efficient market, relying upon price impact arguments and challenging the findings of the Fund’s expert as inadequate. A district court may consider five factors10 in determining whether a security was traded on an efficient market: (1) a large weekly trading volume; (2) the existence of a significant number of reports by securities analysts; (3) the existence of market makers and arbitrageurs in the security; (4) the eligibility of the company to file an S-3 Registration Statement; and (5) a history of immediate movement of the stock price caused by unexpected corporate events or financial releases. Freeman v. Laventhol & Horwath, 915 F.2d 193, 197-98 (6th Cir. 1990); Bovee v. Coopers & Lybrand, 216 F.R.D. 596, 605 (S.D. Ohio 2003). Defendants have not challenged or argued these certification stage. Amgen, 133 S.Ct. at 1200 (citing Halliburton, 131 S.Ct. at 2184). 9 Defendants acknowledge that the materiality showing need not be made prior to class certification. (Doc. No. 115 at 15.) 10 Rather than apply these factors as a checklist, they are to be used as analytic tools by the court to assist in its market efficiency determination. In re Accredo Health, Inc. Securities Litigation, 2006 WL 1716910 at * 10 (W.D. Tenn. April 10, 2006). Here, as in Accredo, the stock was traded in a national security market that is widely regarded as efficient. 16 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 16 of 22 PageID #: 6592 factors but instead rely on their price impact arguments to try to rebut the Plaintiffs’ assertion of an efficient market. (Doc. No. 115 at 16-24.) The Court finds that shares of the Bank’s stock traded in an efficient market because they were traded on the NYSE. Certain markets, such as the NYSE, are well-suited for application of the fraud-on-the-market theory because “[a] well-developed and impersonal market, such as the New York or Pacific stock exchanges, will instantaneously incorporate all publicly available information about a given security into the market price of that security.” Bovee, 216 F.R.D. at 606. Because the Bank’s stock was traded on the NYSE during the class period (Doc. No. 39 at 9), the Court is satisfied that the Fund has established, for purposes of class certification, that the stock traded in an efficient market. d) Rebuttal - Price Impact Defendants argue that they have rebutted Plaintiffs’ allegations of an efficient market by showing that the alleged misrepresentations had no price impact. Plaintiffs are not required to present direct evidence to prove price impact in order to rely on the fraud-on-the-market presumption. Sterling Heights General Employees’ Retirement Sys. v. Prudential Financial, Inc., 2015 WL 5097883 at * 12 (D. N.J. Aug. 31, 2015) (citing Halliburton, 134 S.Ct. at 2414). They can establish entitlement to the presumption through evidence of publicity and market efficiency, an indirect way of showing price impact. Sterling Heights at * 12; Halliburton, 134 S.Ct. at 2415. Before Halliburton, courts around the country held that the presumption of reliance could be rebutted at trial. See, e.g., In re Accredo Health, Inc. at *11 (presumed reliance can be rebutted at trial); In re Polymedica, 432 F.3d at 17 (at the class certification stage, court will not address whether defendants can rebut the presumption of reliance). In Halliburton, however, the Court held 17 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 17 of 22 PageID #: 6593 that defendants must be afforded an opportunity before class certification to demonstrate that an alleged misrepresentation did not actually affect the market price of the stock.11 Willis at * 15. Price impact is the consideration of whether the alleged misrepresentations affected the market price. Id. at *16. The burden to prove lack of price impact by a preponderance of the evidence rests on the defendant in order to rebut the fraud-on-the-market presumption at this stage. Id. at 16; In re Goldman Sachs Group, Inc. Securities Litigation, 2015 WL 5613150 at * 4 and n. 3 (S.D. N.Y. Sept. 24, 2015). Price impact is demonstrated by plaintiffs through either evidence that a stock’s price rose in a statistically significant manner after a misrepresentation or evidence that the stock’s price declined in a statistically significant manner after a corrective disclosure. Willis at 16. Defendants argue that the alleged misstatements in this case did not affect the stock price at the time those statements were made. They assert that this alone sufficiently demonstrates the absence of price impact. (Doc. No. 115 at 17.) To successfully rebut the fraud-on-the-market presumption, however, a defendant cannot simply show that a price did not rise after a misrepresentation. Willis at 16. As explained in Halliburton, price impact (not lack of price impact) can be shown by the plaintiffs through evidence that the price was affected either at the time of the misrepresentation or at the time after a corrective disclosure. Willis at 16 (citing Halliburton at 2414). Analysis of the price impact usually focuses on stock price movement at the time the truth is disclosed. Goldman Sachs at * 6. “So the fact that there was no stock price increase when the statements were made does not suggest a lack of price impact.” Id. In other words, in order to rebut the presumption for class 11 Halliburton held that the defendants may seek to defeat the presumption at the class certification stage through direct as well as indirect price impact evidence. Halliburton, 134 S.Ct. at 2417. 18 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 18 of 22 PageID #: 6594 certification purposes, Defendants must show that the misrepresentation did not in fact affect the stock price; but “affecting the stock price” can occur at the time the misrepresentation is made or at the time the corrective disclosure is given. Willis at * 15. The Fund contends that the price impact occurred at the time the corrective disclosure was made. The Amended Complaint alleges that when Defendants’ “corrective disclosure” was made in July of 2014, the price of BancorpSouth stock tumbled more than 8% the first day and another 1.72% the second day. (Doc. No. 39 at ¶ 93.) Defendants have not rebutted this change in the stock prices at the time of disclosure. Defendants assert that any decline in stock price after the corrective disclosure likely reflects other factors besides the corrective disclosure. Whether Defendants are correct, however, involves merits issues as to causation. The case cited by Defendants, Dura Pharmaceuticals, Inc. v. Broudo, 125 S.Ct. 1627 (2005), dealt with a motion to dismiss, not a motion for class certification, and the Court was analyzing loss causation, not price impact. Loss causation is not price impact. Erica P. John Fund, Inc. v. Halliburton Co., 131 S.Ct. 2179, 2187 (2011). Price impact simply refers to the effect of a misrepresentation on a stock price. Id. For all these reasons, the Court finds that Defendants have not rebutted the fraud-on-the- market presumption for purposes of this Motion, and Plaintiffs are entitled to rely on that presumption. 19 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 19 of 22 PageID #: 6595 Affiliated Ute Presumption Plaintiffs also contend that, with regard to the Defendants’ failures to disclose (as opposed to misrepresentations), they are entitled to the “Affiliated Ute Presumption.” In Affiliated Ute Citizens of Utah v. United States, 92 S.Ct. 1456 (1972), the Supreme Court held that in securities actions involving primarily a failure to disclose, positive proof of reliance is not a prerequisite to recovery. Id. at 1473. “All that is necessary is that the facts withheld be material in the sense that a reasonable investor might have considered them important in the making of this decision.” Id. More recently, the Supreme Court stated that if there is an omission of a material fact by one with a duty to disclose, the investor to whom the duty was owed need not provide specific proof of reliance. Stoneridge Investment Partners, LLC v. Scientific-Atlanta, Inc., 128 S.Ct. 761, 769 (2008). Defendants argue that Plaintiffs have admitted this case does not involve omissions. The sentence from Plaintiffs’ Memorandum in Support of Motion to Dismiss (Doc. No. 64 at 21) that Defendants quote, however, is not such an admission: “Nowhere does Plaintiff allege that Defendants had a stand-alone duty to disclose the existence of [an FDIC investigation].” In context, that sentence begins an explanation of how Defendants, having chosen to speak, had a duty — not an independent, stand-alone duty, but a duty brought about by their choosing to speak — to disclose certain information. (Doc. No. 64 at 21.) Indeed, Plaintiffs allege situations where Defendants’ failure to disclose certain information is what makes the alleged misrepresentations misleading or false. 20 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 20 of 22 PageID #: 6596 Plaintiffs have alleged both omissions and misrepresentations.12 (Doc. No. 39.) Where plaintiffs’ claims are based on a combination of omissions and misstatements, courts have acknowledged the applicability of the Affiliated Ute presumption as to the element of reliance with regard to alleged omissions. Dodona I, LLC v. Goldman, Sachs & Co., 296 F.R.D. 261, 270 (S.D. N.Y. 2014). The Court finds that, for purposes of class certification, the Fund is entitled to the Affiliated Ute presumption as to its failure to disclose claims. Individualized Issues Finally, Defendants maintain that individual issues concerning reliance and damages remain. Under the fraud-on-the-market and Affiliated Ute presumptions, for purposes of class certification, reliance will be presumed. Similarly, Defendants’ argument concerning damages as an individualized issue will be addressed at trial. As noted above, the presence of questions peculiar to each individual member of the class is no bar when liability arose from a single course of conduct. Young, 693 F.3d at 543. There is a “battle of the experts” with regard to damages, and it is unnecessary for the Court to rule on that battle at this time because this is a motion for class certification. If, after class certification, Plaintiffs cannot show that damages are capable of measurement on a class-wide basis, the Court may bifurcate the issues of liability and damages or Defendants may move to decertify the class. CONCLUSION For all these reasons, the Court finds that the Fund’s Motion to Certify the Class (Doc. No. 97) should be GRANTED. 12 The Affiliated Ute Presumption applies to cases involving primarily a failure to disclose, which is not the same as exclusively a failure to disclose. Dodona I, 296 F.R.D. at 269. 21 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 21 of 22 PageID #: 6597 An appropriate Order will enter. ___________________________________ WAVERLY D. CRENSHAW, JR. CHIEF UNITED STATES DISTRICT JUDGE 22 Case 3:14-cv-01564 Document 200 Filed 06/26/17 Page 22 of 22 PageID #: 6598 End October End November End December End January End February End March End April End May1001 CenterState Bank0.00 0.00 200,006.85 310,857.75 238,701.66 415,934.02 305,635.31 391,052.401230 Accounts Receivable Other 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2,700.651300 Prepaid Other0.00 0.00 0.00 3,708.78 0.00 0.00 0.00 0.00Salem Trust-Consolidated1400 Cash and Equivalents0.00 0.00 0.00 0.00 0.00 1,642,999.12 1,694,204.02 1,725,191.891410 Equities0.00 0.00 0.00 0.00 0.00 47,732,657.74 48,262,098.10 48,498,317.491420 Fixed Income0.00 0.00 0.00 0.00 0.00 24,392,461.98 24,535,199.92 24,696,694.301431 American Core Realty0.00 0.00 0.00 0.00 0.00 4,386,990.31 4,474,141.36 4,474,141.361432 RBC Global0.00 0.00 0.00 0.00 0.00 4,761,250.35 4,990,124.91 4,990,124.911433 U.S. Real Estate0.00 0.00 0.00 0.00 0.00 4,666,977.78 4,738,361.26 4,738,361.261450 Accrued Income0.00 0.00 0.00 0.00 0.00 111,574.99 121,168.19 149,720.211461 Due from Brokers0.00 0.00 0.00 0.00 0.00 435,819.78 2,958,750.78 0.001462 Due to Brokers0.00 0.00 0.00 0.00 0.00 (491,821.37) (2,900,188.80) (17,597.98)Salem Trust Total0.00 0.00 0.00 0.00 0.00 87,638,910.68 88,873,859.74 89,254,953.44Regions Bank-Consolidated1500 Cash and Equivalents 2,345,801.45 1,767,720.92 1,723,178.86 1,856,359.20 2,023,051.48 75,627.03 1,318.47 0.001510 Equities41,069,058.38 43,053,308.94 43,993,635.55 44,594,431.76 44,974,282.39 69,761.37 0.00 0.001520 Fixed19,343,939.41 19,576,790.35 19,626,195.13 19,769,941.26 19,967,923.91 11,215.87 0.00 0.001523 Balanced Mutual Funds 4,067,535.06 4,054,617.97 4,108,032.70 4,163,001.27 4,213,484.87 0.00 13,278.57 0.001525 International2,305,946.06 2,260,230.95 2,276,950.73 2,408,487.09 2,424,531.33 0.00 0.00 0.001540 Partnerships-American Core 4,228,877.98 4,242,891.71 4,242,891.71 4,242,891.71 4,230,089.66 0.00 0.00 0.001550 Accrued Income133,417.20 170,203.39 164,121.15 153,631.05 164,051.72 39,581.53 75.93 43.821561 Due from Brokers38,643.60 1,439,955.95 0.00 33,657.52 139,079.06 0.00 0.00 0.001562 Due to Brokers(57,701.15) (1,432,808.87) (87,882.42) (245,262.99) (83,639.85) 0.00 0.00 0.00Regions Bank Total 73,475,517.99 75,132,911.31 76,047,123.41 76,977,137.87 78,052,854.57 196,185.80 14,672.97 43.821633 RBC Global Asset Management 4,412,046.57 4,359,868.17 4,510,932.56 4,723,263.76 4,761,250.35 0.00 0.00 0.001637 U.S. Real Estate Investment 4,461,129.00 4,461,129.00 4,666,978.00 4,666,978.00 4,666,978.00 0.00 0.00 0.001649 ICMA-RC709,102.49 719,453.27 732,072.55 742,423.33 752,296.44 773,497.76 773,497.76 773,497.762000 Accounts Payable(97,537.17) (97,340.79) (172,951.32) (173,146.64) (20,961.72) (47,166.53) (47,166.53) (8,494.00)82,960,258.88 84,576,020.96 85,984,162.05 87,251,222.85 88,451,119.30 88,977,361.73 89,920,499.25 90,413,754.07Palm Beach Gardens Firefighters' Pension FundBalance SheetFY 2017Account DescriptionTOTAL RESERVE FUND (MARKET VALUE): End October End November End December End January End February End March End April End May Year To DateIncome:4000 Employer Contributions 2,882,604.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2,882,604.004100 Employee Contributions 19,657.16 34,147.92 51,142.27 34,122.55 34,437.31 34,283.95 34,017.03 35,364.60 277,172.794190 ICMA-RC DROP Contributions 10,350.78 10,350.78 10,350.78 10,350.78 9,873.11 0.00 0.00 0.00 51,276.23Realized Gain/Loss-Salem Trust4210 Equities0.00 0.00 0.00 0.00 0.00 (9,397.76) (10,391.53) 19,880.77 91.484220 Fixed Income0.00 0.00 0.00 0.00 0.00 5,467.96 33,757.46 (3,365.52) 35,859.90Unrealized Gain/Loss-Salem Trust4310 Equities0.00 0.00 0.00 0.00 0.00 (126,319.51) 601,855.39 447,309.62 922,845.504320 Fixed Income0.00 0.00 0.00 0.00 0.00 79,081.02 30,315.58 19,300.22 128,696.824331 American Core Realty 0.00 0.00 0.00 0.00 0.00 0.00 34,085.28 0.00 34,085.284332 RBC Global0.00 0.00 0.00 0.00 0.00 0.00 228,874.56 0.00 228,874.564333 U.S. Real Estate0.00 0.00 0.00 0.00 0.00 0.00 39,593.31 0.00 39,593.31Realized Gain/Loss-Mgr Held4433 RBC Global Asset Management (51.36) 27,589.14 4,479.37 18.98 16,081.29 0.00 0.00 0.00 48,117.424437 U.S. Real Estate Investment 0.00 0.00 (10,737.00) 0.00 0.00 0.00 0.00 0.00 (10,737.00)Unrealized Gain/Loss-Mgr Held4533 RBC Global Asset Management (66,903.67) (79,584.67) 136,928.16 208,225.20 16,832.18 0.00 0.00 0.00 215,497.204537 U.S. Real Estate Investment 0.00 0.00 213,188.00 0.00 0.00 0.00 0.00 0.00 213,188.004549 ICMA-RC Gain/Loss0.00 0.00 2,268.50 0.00 0.00 21,201.32 0.00 0.00 23,469.824600 Interest & Dividend Income 98,100.41 126,211.44 347,885.51 95,612.36 125,854.89 189,515.86 96,300.01 134,779.87 1,214,260.354710 Securities Litigation0.00 0.00 0.00 136.17 0.00 114.38 0.00 0.00 250.554800 Regions Bank Adjustments (0.04) 0.00 0.00 (0.05) (0.01) 0.00 (153.52) (0.01) (153.63)4806 Assets Txfrd to Salem Trust 0.00 0.00 0.00 0.00 0.00 (76,402,121.34) 4,032.22 0.00 (76,398,089.12)4807 Assets Received from Regions 0.00 0.00 0.00 0.00 0.00 76,523,581.42 0.00 0.00 76,523,581.42Realized Gain/Loss-Regions Bank4810 Equities(1.19) 78,910.28 26,836.65 11,092.75 41,977.91 390,760.44 0.00 0.00 549,576.844820 Fixed(6,662.25) (16,274.53) (9,395.17) (4,668.01) (3,282.37) (6,168.69) 0.00 0.00 (46,451.02)4825 International0.00 (2,646.08) 514.29 0.00 1,330.10 0.00 0.00 0.00 (801.69)Unrealized Gain/Loss-Regions Bank4910 Equities(988,765.20) 1,862,819.04 699,391.14 988,444.15 1,385,251.98 (255.67) 0.00 0.00 3,946,885.444920 Fixed55,569.39 (313,047.03) 126,358.46 (37,073.23) 168,364.69 225.33 0.00 0.00 397.614923 Balanced Mutual Funds (34,309.11) (26,775.78) 26,895.13 38,653.68 34,918.39 0.00 97.10 0.00 39,479.414925 International (102,273.21) 32,573.22 38,759.28 71,053.54 52,916.59 0.00 0.00 0.00 93,029.424940 Partnerships-American Core 0.00 14,013.73 0.00 0.00 (12,802.05) 0.00 0.00 0.00 1,211.68Total Income1,867,315.71 1,748,287.46 1,664,865.37 1,415,968.87 1,871,754.01 699,968.71 1,092,382.89 653,269.55 11,013,812.57End October End November End December End January End February End March End April End May Year To DateExpense:5000 Benefit Payments 119,299.74 119,299.74 119,299.74 123,783.00 128,965.43 128,965.43 131,491.61 131,491.61 1,002,596.305020 Disability Payments0.00 0.00 0.00 6,883.24 6,883.24 6,883.24 6,883.24 6,883.24 34,416.205030 ICMA-RC DROP Benefit Payments 10,350.78 10,350.78 10,350.78 10,350.78 10,350.78 (477.67) 9,831.28 4,965.61 66,073.125100 Refund of Contributions 0.00 0.00 0.00 0.00 36,467.48 0.00 0.00 0.00 36,467.485300 DROP Distributions0.00 0.00 0.00 0.00 172,859.85 0.00 0.00 0.00 172,859.855400 Share Lump Sum Distribution 0.00 0.00 0.00 0.00 303,872.46 0.00 0.00 0.00 303,872.466000 Custodian Fees2,584.55 2,637.45 2,669.26 2,700.65 2,736.12 1,351.48 0.00 0.00 14,679.516020 Investment Consultant Fees 0.00 0.00 7,500.00 0.00 0.00 7,500.00 0.00 0.00 15,000.006040 Investment Management Fee 0.00 0.00 116,659.58 0.00 0.00 15,995.00 0.00 0.00 132,654.586110 Administrator Fees0.00 0.00 0.00 2,200.00 4,875.00 0.00 0.00 7,624.60 14,699.606120 Auditor Fees0.00 0.00 0.00 0.00 3,910.00 0.00 0.00 3,370.00 7,280.006130 Bank Charges0.00 0.00 0.00 65.00 15.00 15.00 25.00 55.00 175.006140 Computer Services0.00 0.00 0.00 450.00 0.00 0.00 0.00 0.00 450.006150 Legal Fees0.00 0.00 0.00 2,223.00 0.00 0.00 0.00 5,500.50 7,723.506160 Postage0.00 0.00 0.00 0.00 17.77 0.00 0.00 78.17 95.946200 Trustee Expenses-Conference 0.00 0.00 0.00 0.00 0.00 1,304.70 1,014.24 0.00 2,318.946220 Membership Fees0.00 0.00 0.00 0.00 660.00 0.00 0.00 0.00 660.006300 Fiduciary Liability Insurance 0.00 0.00 0.00 0.00 0.00 12,166.00 0.00 0.00 12,166.006610 ADR Fees0.00 0.00 14.50 0.00 0.00 22.88 0.00 46.00 83.386730 RBC-Other Expenses 251.93 237.41 228.42 252.40 244.43 0.00 0.00 0.00 1,214.596790 Rounding0.00 0.00 2.00 0.00 0.00 0.22 0.00 0.00 2.22Total Expense132,487.00 132,525.38 256,724.28 148,908.07 671,857.56 173,726.28 149,245.37 160,014.73 1,825,488.67Reserve Fund Last Period 81,225,430.17 82,960,258.88 84,576,020.96 85,984,162.05 87,251,222.85 88,451,119.30 88,977,361.73 89,920,499.25 81,225,430.17Balance To/ From Reserve 1,734,828.71 1,615,762.08 1,408,141.09 1,267,060.80 1,199,896.45 526,242.43 943,137.52 493,254.82 9,188,323.90TOTAL RESERVE FUND 82,960,258.88 84,576,020.96 85,984,162.05 87,251,222.85 88,451,119.30 88,977,361.73 89,920,499.25 90,413,754.07 90,413,754.07Palm Beach Gardens Firefighters' Pension FundStatement of Income and ExpenseFY 2017Account DescriptionAccount Description Fully engaged means experience across cultures, currencies and courtrooms Class aCtion litigation Firm oF the Year LegaL InteLLIgencer national law Journal PLaIntIffs’ HotLIst reCognized as leaders in the shareholder litigation FieldtHe LegaL 500 Fully committed means the trust that we’ll treat your interests like they were our own Kessler Topaz is widely recognized as a leading firm throughout the world in protecting the public against corporate fraud and other wrongdoing. Our lawyers regularly take on the foremost defense attorneys—and win—in class actions, shareholder derivative suits, antitrust litigation, direct action and other complex litigation around the globe. We are proud to have recovered tens of billions of dollars for our clients. leading litigation Firm bencHmark LItIgatIon 2 what we do All of our work is driven by a common goal: to protect investors, consumers, employees and others from fraud, abuse, misconduct and negligence by businesses and fiduciaries. We represent investors and classes worldwide, and are particularly known for our work on behalf of institutional investors. At the end of the day, we have succeeded if you recover assets you had lost as a result of business misconduct. Our lawyers can help you navigate through every stage of a dispute—from assessing potential claims, to motion practice, to trials and through appeals, to settlement negotiations and claims administration. We are skilled advocates not only in court, but also in arbitration and other alternative dispute resolution fora. In addition to obtaining financial compensation, we have been instrumental in achieving significant corporate governance reforms to prevent future violations of law. “ Counsel actively, thoroughly and impressively litigated a complex subject matter (both factually and legally), all the while confronting formidable defense counsel . . .” Securities Fraud Litigation Shareholder Derivative Actions Mergers and Acquisitions Litigation Global Securities Litigation Direct and Opt-Out Actions Fiduciary Litigation Antitrust & Unfair Business Practices Whistleblower Representation Arbitration Portfolio Monitoring and Claims Administration Corporate Governance – Honorable George H. Wu, United States District Court for the Central District of California 3 SeCURiTieS FRAUD LiTiGATiOn Kessler Topaz’s renowned shareholder litigation practice has recovered billions of dollars for defrauded investors around the world. We are aggressive, effective advocates in securities fraud claims against public companies—and their officers, directors and advisors—that misrepresent information and cause harm to their shareholders. Our sophisticated client base is composed of more than 250 institutional investors—including 100+ public pension funds—as well as Taft-Hartley funds, mutual fund managers, asset managers, insurance companies, sovereign wealth funds, hedge funds and other institutional investors in the United States and around the world. representative successes $3.2 billion Tyco international, Ltd.: landmark settlement included the largest securities class action recovery from a single corporate defendant in history $2.425 billion Bank of America/Merrill: settlement resolved allegations of fraud surrounding merger $730 million Citigroup, inc.: second largest recovery ever under Section 11 of the Securities Act $627 million Wachovia Preferred Securities and Bond/notes: one of the most significant cases arising out of the financial crisis $616 million Lehman Brothers: shareholders recover despite Lehman bankruptcy $500 million Countrywide Financial Corp.: litigation raised several issues of first impression in the Ninth Circuit “it is difficult to overstate the complexity of [the litigation],” which also “put [Plaintiffs] at the cutting edge of a rapidly changing area of law.” – The Honorable Paul Barbadoro, United States District Court for the District of New Hampshire 4 Mergers and acquisitions can offer great opportunities for shareholders to increase value. But they also present temptation for self-dealing and dishonesty by directors and officers, often at shareholder expense. We give shareholders the next best thing to a seat at the negotiating table—strong, effective representation in cases alleging unfairness in a transaction’s price or process. Each case is different, whether we seek additional merger consideration or non-monetary deal terms that increase shareholder value. Unlike many of our competitors, Kessler Topaz has proven experience bringing massive transactional cases to trial—and winning, as we did in Southern Peru Copper ($2 billion) and Dole Foods ($148 million). In matters both large and small, our creative and aggressive approach and trial readiness have helped our clients recover billions of dollars of increased merger consideration both through trial and through pre-trial settlements. RePReSenTATive SUCCeSSeS $2 billion Southern Peru Copper Corp.: both the largest trial verdict and largest damages award in Delaware Chancery Court history $148 million Dole Food Company, inc.: the second-largest post- trial verdict in merger litigation in Delaware Chancery Court history $64 million Cole Real estate investments: additional merger consideration after shareholders challenge REIT sale $26 million Harleysville Mutual: expedited injunction hearing for policyholders after mutual insurer sold to Nationwide $24 million GSi Commerce: case challenged insider dealings in eBay acquisition MeRGeR & ACqUiSiTiOn LiTiGATiOn When corporate fiduciaries abuse their power, shareholder derivative actions can balance the scales. We have recovered millions of dollars from wayward fiduciaries in both high-profile matters and smaller disputes. Our success stories involve a wide array of corporate misconduct, ranging from executive compensation abuses, to related-party transactions, to the “backdating” of stock options. RePReSenTATive SUCCeSSeS $62 million Comverse Technology, inc.: overhauled the Company’s corporate governance and internal controls $6 million Helios Closed-end Funds: recovered for mutual funds in action authorized by board of directors $4.9 million Under Armour, inc.: monetary and corporate governance relief for minority stockholders in dilutive recapitalization $3.25 million China Agritech, inc.: cash recovery for stockholders of Chinese “reverse merger” company SHAReHOLDeR DeRivATive ACTiOnS 5 .GLOBAL SeCURiTieS LiTiGATiOn investment strategies transcend national borders. Unfortunately, so does fraud. Our Global Securities Litigation group is dedicated to helping investors prosecute corporate fraud claims and recover assets around the world. international Leadership Through our border-crossing work, we have developed a deep understanding of foreign laws and procedures, as well as important relationships with lawyers and experts in more than a dozen countries. Our international experience gives clients a unique advantage in pursuing claims on a global basis. Today, global shareholder litigation continues to evolve, as new jurisdictions begin to allow multiparty or group shareholder actions and debate class action procedures. We are committed to remaining at the forefront of these developments and expanding our resources to best serve shareholders around the world. “We like the flexible and professional way Kessler Topaz has been working with us in different cases and their filing of settlement claims is invaluable.” representative successes €1.2 Billion Fortis Bank: one of the largest securities settlements outside the United States $352 million Royal Dutch Shell: landmark settlement opens doors to class recovery in the Netherlands $92 million Olympus Corporation: one of the largest securities-fraud recoveries ever achieved in Japan –Richard Gröttheim, CEO AP7 – Seventh Swedish National Pension Fund 6 .Looted pension funds, fraudulent investments and vanishing profits are the stuff of headlines—and nightmares. When trusts and their beneficiaries find themselves on the losing end of fiduciary mismanagement, we help them recover assets believed to be gone forever. Our Fiduciary Litigation group has recovered more than $1 billion for clients victimized by fiduciary failures. We have served as lead or co-lead ERISA counsel in some of the most significant cases in history. FiDUCiARy LiTiGATiOn Class action litigation is not for every investor in every case. if you’ve been injured by corporate misconduct, there may be other routes to recovery. With experience in hundreds of shareholder actions worldwide, Kessler Topaz has the skill and perspective to help you analyze the options and choose the one that’s right for you. Know your Options In a direct action, an investor or small group of investors “opt-out” of a pending or potential class action against a publicly traded company, its officers or directors, and/or its advisors. Instead of being part of a class, your fund pursues its own claim in its own lawsuit. We are litigating dozens of opt-out cases on behalf of institutional investors throughout the country and the world. DiReCT AnD OPT-OUT ACTiOnS representative successes $280 million Bny Mellon Bank, n.A.: BNY Mellon settled claims alleging that it breached its fiduciary duties under common law, and committed a breach of its contractual obligations under the securities lending agreements. $150 million JPMorgan Chase Bank, n.A.: JPMorgan settled claims for allegedly breaching its fiduciary duties under the Employee Retirement Income Security Act (ERISA). $79 million Global Crossing, Ltd.: Global Crossing settled claims that it allegedly breached its fiduciary duties. In 2004, this represented the largest recovery received in a company stock ERISA class action. $75 million AiG, inc: AIG settled claims with Transatlantic Holdings, Inc., who allegedly breached its fiduciary obligations as investment advisor. 7 “. . . the Court finds that KTMC is one of the most experienced eRiSA litigation firms in the country, with particular expertise in the area of eRiSA breach of fiduciary class actions . . .” –Vicki Miles-LaGrange, Chief United States District Judge, United States District Court for the Western District of Oklahoma AnTiTRUST & UnFAiR BUSineSS PRACTiCeS Competitive markets are at the heart of the U.S. economy. Kessler Topaz helps protect competition against those who would curtail choices, control prices or otherwise interfere with fair markets. Help for Homebuyers Our RESPA (Real Estate Settlement Procedures Act) Litigation practice is nationally known for actions that challenge unfair lending and related insurance practices. We have been selected as lead or co-lead counsel in cases against lenders and mortgage servicers that: • Refer borrowers to private mortgage insurers in return for kickbacks or fee-sharing • Force-place borrowers into grossly over- priced homeowners insurance or flood insurance in return for kickbacks In recent RESPA litigation against 13 major national lenders, we recovered millions of dollars on behalf of affected borrowers and have several actions pending. representative successes $150 million Flonase: millions recovered in pharmaceutical monopoly case $69 million Bank of America/WaMu: consolidated class recovers WaMu losses $36 million Remeron: consumers allege patent claims would create unlawful monopoly 8 For many of our clients, arbitration is an integral part of the dispute resolution process. Our lawyers are seasoned advocates in domestic and international arbitration, handling challenging disputes before panels across the United States and europe. An Approach That Works We understand the unique rules and procedures of arbitration and how to work within the arbitration context in ways that are most advantageous to our clients. Representing institutional investors, corporate entities and others, we have achieved significant arbitration results, such as a $75 million award for Transatlantic Holdings, Inc. and its subsidiaries in a subprime mortgage dispute against AIG. In addition, we advise on alternative dispute resolution methods such as mediation and can counsel you on the best options for any given situation. We combine our understanding of the arbitration process with industry knowledge, geographic reach and a commitment to the highest standards of litigation. We communicate clearly, respond quickly and strive to maintain your trust throughout the arbitration process and beyond. it takes conscience, courage and conviction to bring wrongdoing to light. Kessler Topaz knows how to use the whistleblower laws to protect and reward those who uncover wrong-doing and step forward to fight it. Champions for Whistleblowers Whistleblowers are the unsung heroes of the marketplace, often risking career and reputation harm to report illegal conduct and to do the right thing in the face of corporate fraud. If you have information about a fraud and are considering becoming a whistleblower, we can help you make a compelling case to authorities, protect yourself from retaliation and claim a share of the money the government recovers. At Kessler Topaz, you’ll find lawyers who have dedicated their careers to representing whistleblowers. Fighting corporate fraud is what we do—all day, every day. Our whistleblower team includes lawyers who have worked as federal and state prosecutors, as SEC enforcement lawyers and as litigators with decades of international experience in complex health care, pharmaceutical, securities, corporate and government contract fraud cases. Clients also have access to our renowned Investigative Services Division—which includes former law enforcement agents known for their relentless pursuit of evidence. WHiSTLeBLOWeR RePReSenTATiOn ARBiTRATiOn 9 PORTFOLiO MOniTORinG AnD CLAiMS ADMiniSTRATiOn For institutional fiduciaries, monitoring and protecting investments is as important as selecting them. But how do you keep track of a diverse, active, global securities portfolio without creating a more-than-full-time job? Our proprietary Securities Tracker program is the answer. Securities Tracker Makes it easy Offered at no cost to our institutional clients, Securities Tracker finds every securities action that impacts your fund, puts it on your radar screen early and monitors it all the way through resolution and disbursement of any recovery. Simply put, Securities Tracker is a must-have solution for fulfilling your fiduciary obligations. The Securities Tracker program includes: • New case summaries and analyses • Quarterly reports • Email alerts • Claims administration auditing and filing • Settlement chart Up-to-Date information Securities Tracker works 24/7, 365 days a year. So even when you’re at a conference, on an airplane or in another time zone, we stay on top of your portfolio. Learn more and see a demo at www.ktmc.com/securities-tracker. CORPORATe GOveRnAnCe Corporate governance doesn’t just happen in boardrooms. it affects every aspect of a business, every day. When you want to make a tangible impact on how a company is run, corporate governance is the place to start. We have helped our clients implement creative, effective governance changes in diverse areas, including: • Director nominations • Director election procedures • Required disclosures for shareholder voting • Executive compensation policies • Internal and external audit functions • Worker safety Our lawyers will listen carefully to your concerns, tailor a strategy to your unique circumstances and adhere to the highest standards of client service. “Kessler Topaz’s claims filing service is an added value to the strong litigation skills they are providing to our fund. They have helped us recover settlement dollars we would have otherwise missed and served as lead counsel for us as well.” –David H. Prince, Retirement Administrator Imperial County Employees Retirement System 10 KTMC.COM COnTACT US Darren J. Check, esquire Please direct all inquiries regarding this publication to Darren J. Check, esquire, at 610.822.2235 or dcheck@ktmc.com Fully commited means the trust that we’ll treat your interests like they were our own 280 King of Prussia Rd. Radnor, PA 19087 P 610.667.7706 F 610.667.7056 One Sansome St., Suite 1850 San Francisco, CA 94104 P 415.400.3000 F 415.400.3001 Shareholder Litigation Counsel, Securities Monitoring and Claims Administration for the City of Palm Beach Gardens Firefighters' Pension Fund 10500 North Military Trail Palm Beach Gardens, FL 33410 1 Thank you for the opportunity to provide you with information about Kessler Topaz Meltzer & Check, LLP (“Kessler Topaz” or the “Firm”) and how we can assist the City of Palm Beach Gardens Firefighters' Pension Fund (the “Fund”) in the identification, evaluation, management and prosecution of securities class action cases and claims. Below you will find summary information on our Firm and the services that we provide. Shareholder Litigation Counsel Since 1987, Kessler Topaz has specialized in the prosecution of securities class actions and has grown into one of the largest and most successful shareholder litigation firms in the field. With offices in Radnor, Pennsylvania and San Francisco, California, the Firm is comprised of 102 attorneys as well as an experienced support staff consisting of over 80 paralegals, in-house investigators, legal clerks and other personnel. Kessler Topaz has developed an international reputation for excellence and has extensive experience prosecuting securities fraud actions. For the past several years, the National Law Journal has recognized Kessler Topaz as one of the top securities class action law firms in the country. In addition, the Legal Intelligencer recently awarded Kessler Topaz with its Class Action Litigation Firm of The Year award. Lastly, Kessler Topaz and several of its attorneys are regularly recognized by Legal500 and Benchmark: Plaintiffs as leaders in our field. The Firm primarily represents institutional investors from public and Taft-Hartley pension funds, to mutual fund advisors, sovereign wealth funds, hedge funds and insurance companies. Over the last two decades the Firm has seen steady growth in both our client base and roster of significant shareholder litigation cases we are prosecuting. Kessler Topaz currently represents, advises, and works with many of the largest public pension funds and other institutional investors in the United States and around the world. Some examples of our clients include the California State Teachers’ Retirement System, the New York State Common Retirement Fund, the Commonwealth of Pennsylvania State Employees Retirement System, the Pennsylvania Public School Employees Retirement System, the Ohio State Retirement Systems, the Washington State Investment Board, the North Carolina Retirement System, the State of Connecticut Retirement Plans & Trust Funds, the Iowa Public Employees’ Retirement System, PGGM - Dutch National Pension Fund, Forsta AP-Fonden – First Swedish National Pension Fund, Fjarde AP-Fonden – Fourth Swedish National Pension Fund, Sjunde AP-Fonden – Seventh Swedish National Pension Fund, ATP Arbejdsmarkedets Tillaegspension – Danish National Pension Fund, Danske Invest Administration A/S and Nordea Invest Fund Management A/S. Most recently Kessler Topaz was retained by the Alaska Permanent Fund Corporation, the State of Alaska Department of Revenue (Treasury Division), Dimensional Fund Advisors LP, Aberdeen Asset Management, Delaware Investments, the Russell Investment Company Funds, and Manning & Napier, to litigate claims related to the massive fraud at Petróleo Brasileiro S.A. (Petrobras). In addition, the Firm represents a broad base of county, municipal, and Taft-Hartley pension funds throughout the country, including 24 Pennsylvania County retirement systems, Los Angeles County Employees Retirement Association, Alameda County Employees’ Retirement Association, San Diego City Employees’ Retirement System, Clayton County, Georgia Public Employee Retirement System, the Firemen’s Retirement Fund of St. Louis, the City of Alpharetta Combined Defined Benefit Pension Plan, the Fort Worth Employees’ Retirement Fund, the City of Austin Police Retirement System, Key West Police and Fire Pension Board of Trustees, the City of Fort Lauderdale General Employees’ Retirement System, the City of Oakland Police & Fire Retirement System, City of Knoxville Employees’ Pension System, the Employees’ Pension Plan of the City of Clearwater, Florida, 2 the Imperial County Employees’ Retirement System, Teamsters Local 272, Iron Workers District Council (Philadelphia & Vicinity) Retirement and Pension Plan, Iron Workers Local 405 Annuity Fund, 1199 SEIU Healthcare Employees, the Equity-League Pension & Health Trust Fund, American Federation of Television & Radio Artists Health & Retirement Funds, American Federation of Musicians and Employers’ Pension Fund, the Massachusetts Laborers, the Buffalo Laborers’ Benefit Funds, IBEW Local 237, Teamsters Union No. 142 Pension Trust Fund, and the Washington State Plumbers & Pipefitters. Attached as “Exhibit A” please find the Firm’s complete institutional investor client list. Currently, Kessler Topaz is serving as lead or co-lead counsel in many of the largest and most significant securities actions currently pending in the United States, including actions against: Qualcomm, Allergan, Inc., Pfizer and Ocwen Financial Corporation, among others. As demonstrated by the magnitude of these high-profile cases, we take seriously our role in advising clients to seek lead plaintiff appointment in cases, paying special attention to the factual elements of the fraud, the size of losses and damages, and whether there are viable sources of recovery. Additionally, the Firm has a robust shareholder Derivative and Mergers & Acquisition Litigation Department which has been a leader in prosecuting shareholder actions in state and federal courts across the country. This Department has been at the forefront of representing institutional investors in all types of shareholder derivative actions, including cases on behalf of companies such as Monster Worldwide, Southwest Airlines, and Comverse Technology. These actions have focused on corporate governance abuses, such as the recent options backdating scandal, excessive executive compensation, and conflict transactions with controlling shareholders. This Department also specializes in takeover litigation, and actively representing institutional investors in actions where shareholders are not receiving fair value for their investments. Notable recent takeover actions include Genentech, Inc., Amicas, Inc., American Italian Pasta Company and GSI Commerce, Inc. Finally, Kessler Topaz is very proud of its recent trial experience in cases against (or on behalf of) Longtop Financial Technologies Ltd., Southern Peru Copper Corporation, Dole Foods Co., Inc., and BankAtlantic Bancorp. Our trials against BankAtlantic (2010) and Longtop (2014) were only the tenth and thirteenth trials, respectively, to reach a verdict since the enactment of the Private Securities Litigation Reform Act of 1995 (“PSLRA”). Separately, in October 2011 and February/March 2015, the Firm concluded trials in the Delaware Court of Chancery in stockholder actions on behalf of Southern Peru Copper Corp. and former Dole Foods Co., Inc. shareholders. In Southern Peru, following a week- long trial, Kessler Topaz secured the largest damage award in Delaware Chancery Court history -- $2 billion. This award was upheld by the Delaware Supreme Court in August 2012. In Dole, following a nine day trial, Kessler Topaz won a $148 million verdict -- representing the second-largest post-trial verdict ever in merger litigation, behind only the Firm’s landmark $2 billion verdict in Southern Peru. Kessler Topaz has recovered billions of dollars in the course of representing defrauded shareholders from around the world and takes pride in the reputation we have earned for our dedication to our clients. Kessler Topaz devotes significant time to developing relationships with its clients in a manner that enables the Firm to understand the types of cases they will be interested in pursuing and their expectations. Further, the Firm is committed to pursuing meaningful corporate governance reforms in cases where we suspect that systemic problems within a company could lead to recurring litigation and where such changes also have the possibility to increase the value of the underlying company. 3 Shareholder Litigation Highlights In re Bank of America Corp. Securities, Derivative, and Employee Retirement Income Security Act (ERISA) Litigation Plaintiffs asserted claims for violations of the federal securities laws against Bank of America Corp. (“BoA”) and certain of BoA’s officers and board members relating to BoA’s merger with Merrill Lynch & Co. (“Merrill”) and its failure to inform its shareholders of billions of dollars of losses which Merrill had suffered before the pivotal shareholder vote, as well as an undisclosed agreement allowing Merrill to pay up to $5.8 billion in bonuses before the acquisition closed, despite these losses. On September 28, 2012, the Parties announced a $2.425 billion case settlement with BoA to settle all claims asserted against all defendants in the action. BoA also agreed to implement significant corporate governance improvements. The settlement, reached after almost four years of litigation with a trial set to begin on October 22, 2012, amounts to 1) the sixth largest securities class action lawsuit settlement ever; 2) the fourth largest securities class action settlement ever funded by a single corporate defendant; 3) the single largest settlement of a securities class action in which there was neither a financial restatement involved nor a criminal conviction related to the alleged misconduct; 4) the single largest securities class action settlement ever resolving a Section 14(a) claim (the federal securities provision designed to protect investors against misstatements in connection with a proxy solicitation); and 5) by far the largest securities class action settlement to come out of the subprime meltdown and credit crisis to date. In re Southern Peru Copper Corp. Derivative Litigation On October 14, 2011, following a week-long trial, Kessler Topaz and its Delaware co-counsel secured the largest damage award in Delaware Chancery Court history — a $2 billion derivative judgment against Southern Peru’s majority shareholder Grupo Mexico. The litigation stemmed f rom Southern Peru’s 2005 acquisition of Minera Mexico, a private company owned by Grupo Mexico, for more than $3 billion in Southern Peru stock. Plaintiffs alleged that the private company was worth more than a billion dollars less, but that Southern Peru’s board had approved this conflicted transaction in deference to its majority shareholder’s interests. Discovery in the case spanned years and continents, with depositions in Peru and Mexico. In re Lehman Brothers Equity/Debt Securities Litigation Plaintiffs alleged that the registration statements and prospectuses used to market Lehman’s numerous offerings leading up to its bankruptcy contained false and misleading information and omitted material facts regarding Lehman’s net leverage, risk management and concentration of risks. A $616 million settlement was reached on behalf of shareholders — $426 million of which came from various underwriters of the Offerings, representing a significant recovery for investors in this now bankrupt entity. In addition, $90 million came from Lehman’s former directors and officers (which is significant considering the diminishing assets available to pay any future judgment) as well as $99 million from Lehman’s auditor Ernst & Young. In re Wachovia Preferred Securities and Bond/Notes Litigation This recovery of $627 million on behalf of purchasers of certain Wachovia Corporation preferred securities is one of the most significant recoveries from litigation arising out of the financial crisis. Plaintiffs alleged that the registration statements, prospectuses and prospectus supplements used to market the Offerings contained materially false and misleading statements and omitted material information. The settlement included a $37 million recovery from the company’s outside auditor. 4 In re Countrywide Financial Corp. Mortgage-Backed Securities Litigation This settlement in the amount of $500 million on behalf of investors who purchased mortgage-backed securities issued by Countrywide Financial Corporation (“Countrywide”) represents the largest MBS class action recovery under the Securities Act in history. Plaintiffs alleged that Countrywide and various of its subsidiaries, officers and U.S. investment banks violated Sections 11, 12(a) (2) and 15 of the Securities Act of 1933 by making materially false and misleading statements in over 450 prospectus supplements relating to the issuance of more than $300 billion in Subprime and Alt-A MBS and the quality of the loans underlying the MBS. The matter further alleged that when information pertaining to the loans materialized, the value of the MBS declined, damaging investors. The settlement, which received final court approval on December 5, 2013, was achieved through prolonged mediation after more than five years of hard fought litigation. In re Citigroup Inc. Bond Litigation This litigation was filed on behalf of purchasers of 48 offerings of Citigroup preferred stock and bonds issued from May 2006 through August 2008 (the “Offerings Period”). Bond plaintiffs alleged that throughout the Offerings Period, Citigroup raised billions of dollars from investors in a series of public offerings while misrepresenting its exposure to toxic assets linked to residential mortgage-backed securities. Plaintiffs also alleged that Citigroup materially understated the loss reserves for its portfolio of high-risk residential mortgage loans, and falsely stated that risky assets held in off-balance sheet entities known as structured investment vehicles (“SIVs”) were of high credit quality. The $730 million settlement reached in the case was approved by the Court on August 20, 2013 and represents the second- largest recovery in securities class-action litigation ever brought on behalf of bond investors. In re Tyco International, Ltd. Securities Litigation This landmark $3.2 billion settlement on behalf of investors included the largest securities class action recovery from a single corporate defendant in history as well as the second largest auditor settlement in securities class action history at the time. Tenet Healthcare Corp. Securities Litigation This recovery of over $280 million on behalf of investors included a substantial monetary commitment by the company, personal contributions from individual defendants, the enactment of numerous corporate governance changes, as well as a substantial recovery from the company’s outside auditor. In re Dole Food Co., Inc. Stockholder Litigation Kessler Topaz filed this stockholder class action alleging that Dole’s long-time controlling stockholder and chairman, David Murdock, and Dole’s president and long-time general counsel, C. Michael Carter, breached fiduciary duties owed to Dole’s public stockholders in connection with Murdock’s buyout of the public stockholders in a deal that closed on November 1, 2013. Kessler Topaz sought to force Murdock to pay a fair price for Dole’s stock, above the $13.50 per share that Murdock had paid in the take-private transaction. Acting as co-lead counsel for a certified class of former Dole stockholders, and after rebuffing Murdock and Carter’s efforts to have the case dismissed before trial, Kessler Topaz conducted a nine-day trial before the Delaware Court of Chancery in February and March 2015. In August 2015, the court issued its verdict in a detailed, 108-page post-trial opinion, finding that Murdock and Carter “primed the market for the freeze-out by driving down Dole’s stock price” and provided the company’s outside directors with “knowingly false” information and intended to “mislead the board for Mr. Murdock’s benefit.” Because of the “fraud” perpetrated by Murdock and Carter, the court ruled that the former Dole public stockholders were entitled to an additional $2.74 per share, or approximately 5 $148 million in total, plus pre-and-post judgment interest. This verdict represents the second-largest post-trial verdict ever in merger litigation, behind only Kessler Topaz’s landmark 2011 $2 billion verdict in In re Southern Peru. In re Genentech, Inc. Shareholders Litigation This shareholder litigation surrounded the July, 2008 attempt by Roche Holdings, Inc. to acquire Genentech for $89 per share. The litigation resulted in the companies entering into an amended affiliation agreement, which allowed a negotiated transaction between Roche and Genentech to close, and enabled Roche to acquire Genentech for $95 per share, approximately $3.9 billion more than Roche offered in its hostile tender offer. In re Monster Worldwide, Inc. Stock Option Derivative Litigation This derivative litigation resulted in the recipients of backdated stock options being forced to disgorge more than $32 million in unlawful gains back to the Company plus the implementation of significant corporate governance measures. International Shareholder Litigation Litigating Cases Outside the U.S. Kessler Topaz has been at the forefront of representing institutional investors in non-U.S. jurisdictions as a growing number of potential claims are barred from being brought in U.S. Courts. The Firm is currently actively involved in representing clients in shareholder litigation in the Netherlands, France, Germany, Japan, Canada, Portugal and the United Kingdom. In 2010, the Supreme Court of the United States significantly limited certain aspects of investor rights. Specifically, Morrison v. National Australia Bank eliminated the right of U.S. investors to seek redress from fraud when they purchase shares on a non-U.S. exchange. In an increasingly global market, this ruling has already proven to present significant hurdles for U.S. pension funds. Some recent examples of cases where U.S. investors could not effectively pursue their claims are those against Volkswagen, UBS, Toyota, BP, Fortis, and Royal Bank of Scotland to name just a few. Having a law firm in place that can monitor, provide legal guidance on, and pursue these claims outside the U.S. is of growing importance to pension funds. Kessler Topaz was co-counsel in the groundbreaking Royal Dutch Shell European Shareholder Litigation case that that recovered $352 million on behalf of non-U.S. investors in the Dutch Enterprise Court, relating to Royal Dutch Shell plc’s 2004 restatement of oil reserves. This settlement of securities fraud claims on a class-wide basis under Dutch law was the first of its kind, and sought to resolve claims exclusively on behalf of European and other non-United States investors. Uncertainty over whether jurisdiction for non-U.S. investors existed in a 2004 class action filed in federal court in New Jersey prompted a significant number of prominent European institutional investors from nine countries, representing more than one billion shares of Shell, to actively pursue a potential resolution of their claims outside the United States. Among the European investors which actively sought and supported this settlement were Alecta pensionsförsäkring, ömsesidigt, PKA Pension Funds Administration Ltd., Swedbank Robur Fonder AB, AP7 and AFA Insurance, all of which were represented by Kessler Topaz. 6 This case challenged the Firm a great deal, requiring mastery of non-U.S. class action law, extraordinary travel requirements, liaising with local Dutch counsel, and the uncertainty of how the litigation would conclude. Ultimately, the Firm made the decision to pursue this action not only in order to provide an avenue for recovery for our clients, but also to gain invaluable international litigation experience. The Firm has been able to use the Royal Dutch Shell litigation model as a template for pursuing actions that must be pursued outside of the United States. Indeed, Kessler Topaz has successfully investigated, organized, funded, and represented large groups of institutional investors in the following actions that have reached a successful resolution: 1. On behalf of a number of institutional investors, the Firm pursued a case in Tokyo, Japan against Olympus Corp. The case against Olympus was based on allegations that Olympus and certain of its officers and directors violated their duties under Japanese Company Law and committed accounting and securities fraud between 1998 and 2011. The allegations against Olympus stemmed from Olympus’ public disclosure in November 2011 concerning the falsity of its financial statements. On June 28, 2012, we filed a complaint against in Tokyo on behalf of 47 plaintiffs with over ¥ 19 billion in claimed damages. In June 2013, we filed a second complaint on behalf of 41 additional plaintiffs with total claims for over ¥ 16 billion in damages Following the filing of the second complaint, Olympus agreed to mediation and, a third group of 12 claimants, who had not previously filed a complaint, were also added to the claims. Kessler Topaz and its partners were able to convince Olympus to agree to mediation. Kessler Topaz was an active participant in the mediation and successfully negotiated an ¥11 billion (approximately $90 million) settlement with Olympus. 2. In January of 2011, the Firm and its partners established a Dutch Foundation and filed a claim on behalf of more than 200 institutional investors with €2 billion in losses against Fortis Bank, N.V. (Fortis) and its successor companies BNP Paribas and Ageas NL. The case against Fortis arose out of the subprime mortgage crisis and alleged fraud in connection with the company’s failed 2007 attempt to acquire Dutch bank ABN Amro Holding NV (ABN Amro). Specifically, we alleged that Fortis misrepresented the value of its collateralized debt obligations, its exposure to subprime-related mortgage-backed securities, and the extent to which the decision to acquire ABN Amro jeopardized its solvency. After the acquisition failed, Fortis encountered financial difficulties and broke up in the fall of 2008. Its investors lost as much as 90% of the value of their investments. Our lawsuit survived rigorous jurisdictional challenges before both the Utrecht District Court and the Dutch Court of Appeals. An appeal (on the jurisdictional challenges) to the Dutch Supreme Court (and possibly the European Court of Justice) was pending as were the proceedings on the merits, however, the Firm helped successfully negotiate a settlement agreement with the defendants for $1.3 billion. The settlement is currently pending approval by the Dutch Courts. Beyond these two group actions, the Firm has also taken an active role in pursuing securities class action litigation in Canada in order to protect the interests of the Firm’s clients trading securities in Canadian markets. For example, Kessler Topaz was U.S. counsel to a European institution serving as a named plaintiff on behalf of investors pursuing Canadian securities claims against Agnico Eagle Mines Limited (Agnico). In this capacity, the Firm assisted Canadian counsel in developing and prosecuting claims arising from Agnico’s failure to disclose ongoing operational issues at its Goldex mine prior to the suspension of mining operations at the mine in October 2011. In February 2016, courts in Ontario and Quebec approved a CDN$17 million settlement of the claims against Agnico. The Agnico 7 settlement is notable in that a companion case in the U.S. (which covered purchasers of Agnico’s stock on a U.S. stock exchange and was based on nearly identical facts) had previously been dismissed. In addition to these successfully concluded cases, the Firm is currently engaged in representing clients in shareholder litigation in the following actions outside the United States: 1. The Firm is representing and funding a number of institutional investors in a direct action venued in Paris, France, against Vivendi Universal, S.A. and Jean-Marie Messier (Vivendi’s former CEO) arising from the facts tried in the securities class action In re Vivendi Universal Securities Litigation in the Southern District of New York. The Paris suit represents investors who purchased Vivendi’s securities on the Paris Bourse and whose claims were excluded from the U.S. litigation due to the Supreme Court’s decision in Morrison v. National Australia Bank. 2. The Firm, in partnership with local Canadian firms, is litigating two class actions in Canada against Sino-Forest and Valeant Pharmaceuticals International, Inc. in an effort to protect investments our clients made on the Toronto exchange. Our involvement has allowed us to assist our clients in pursuing litigation in Canada. At the same time, and because securities fraud class actions are relatively new in Canada, we have been able to offer the Canadian firms our expertise in prosecuting the cases. In the Sino-Forest case, Judge Perell of the Ontario Superior Court of Justice recognized the value of our involvement when he decided the carriage motion. In the Reasons for Decision, Judge Perell noted that Kessler Topaz has “a very high profile and excellent reputation as counsel in securities class action lawsuits in the United States.” In Valeant, Kessler Topaz is serving as U.S. counsel to a European client seeking to represent investors who purchased the Company’s shares on the Toronto Stock Exchange. The Valeant action was filed following revelations that the Company concealed its reliance on affiliated specialty pharmacies to distribute certain of its high-priced drugs and improperly recording sales to these specialty pharmacies in order to artificially inflate revenue. The Company’s reliance on affiliated specialty pharmacies is currently the subject of a probe by the United States Department of Justice. In both the Sino-Forest and the Valeant cases the Firm has been active in assisting Canadian counsel with litigation strategy, crafting legal arguments, preparing and defending client depositions, and settlement negotiations. In Sino-Forest, while the action against the company is still pending, we helped negotiate a claims settlement with Ernst & Young, the C ompany’s auditor, for approximately $117 million Canadian. The $117 million settlement is the largest payment ever made by an auditor in Canada to settle a class action. 3. The Firm is representing and funding a large group of institutional investors in an action against Royal Bank of Scotland (“RBS”) for its £44 billion loss in market value stemming from facts which suggest that RBS materially mislead investors with respect to its true exposure to subprime-related assets and collateralized debt obligations and inflated the value of its assets including those assets it acquired from the Dutch bank ABN Amro. 4. The Firm is representing and funding a group of institutional investors who hold senior Banco Espirito Santo bonds in a recently filed action against the Bank of Portugal. The action is an administrative challenge against the Bank of Portugal’s December 29, 2015 decision to re- 8 transfer certain senior notes from Novo Banco S.A. back to the now defunct Banco Espirito Santo. When Banco Espirito Santo collapsed in August of 2014, the Bank of Portugal created a new bank, Novo Banco, and transferred all assets and some bonds to Novo Banco. On December 29, 2015, the Bank of Portugal decided to retransfer €2 billion worth of bonds from Novo Banco (which has assets) back to Banco Espirito Santo (which has no assets and is currently in bankruptcy proceedings). The result is that bondholders lost at least 90% of the value of their bonds. 5. The Firm is representing and funding a group of over 500 institutional investors in securities litigation in Germany against Volkswagen and Porsche concerning Volkswagen’s “dieselgate” emissions scandal that caused substantial monetary damages to Volkswagen and Porsche shareholders. In March of 2016, the firm filed an initial complaint against Volkswagen on behalf of 278 institutional investors alleging €3.25 billion in damages, and in September of 2016 the firm filed a second complaint against Volkswagen on behalf of 263 institutional investors alleging €1.25 billion in damages and a complaint against Porsche on behalf of 147 institutional investors alleging €547 million in damages. Altogether the Firm’s group is the largest group of investors pursuing action against Volkswagen and the claims represent more than 50% of the total claims filed in Germany against Volkswagen. The litigation against Volkswagen and Porsche is ongoing. 6. The Firm is representing a number of institutional investors in securities litigation in Tokyo, Japan against Toshiba Corporation (Tokyo District Court, Heisei 28 (wa) 20446). The first complaint was filed on behalf of 45 institutional investors on June 22, 2016. The complaint claims a total of ¥ 16,396,952,512 (approximately $245 million) in damages and alleges that Toshiba violated the Japanese Financial Instruments & Exchange Act and the Japanese Civil Code by issuing false and misleading statements with regard to its accounting practices over the past several years. Monitoring Cases Outside the U.S. The Morrison decision has resulted in a proliferation of shareholder litigation cases being filed outside the United States. Not only has Kessler Topaz been at the forefront of representing institutional investors in non-U.S. jurisdictions, but the Firm is also able to monitor these cases for our clients and ensure they are participating in any and all settlement opportunities – something U.S.-based custodian banks are not equipped to do. To that end, Kessler Topaz works with law firms in a number of countries around the world, including the Netherlands, France, Canada, Australia, United Kingdom, Germany, Sweden, Denmark, Italy and Israel, to assist the Firm with tracking cases and settlements in their respective jurisdictions, and also with evaluation trends in shareholder litigation. We are currently following more than 100 non-U.S. jurisdiction actions for our clients, and have alerts set up in 13 countries to advise us each time a new action is filed. For these many reasons we feel that the Firm is especially well positioned to serve and represent institutional investors in an increasingly global market. Pursuing Litigation/Case Evaluation In determining whether to recommend the filing of a lead plaintiff motion or individual action, Kessler Topaz has a Case Evaluation Department consisting of six attorneys whose primary responsibility is to evaluate and analyze the merits of potential class actions or opt-out suits. These 9 attorneys – who focus their practice on servicing the needs of institutional investors – collectively have more than 50 years of experience litigating federal securities class action and opt-out lawsuits in various jurisdictions. We believe that by committing an entire team of skilled securities litigators to the case evaluation process, we are uniquely positioned to provide timely, comprehensive, and highly detailed analysis to our clients regarding the merits and risks of a particular course of action, including analysis of changes in the law and real world difficulties in prosecuting cases. We typically employ the following methodology for analyzing cases: When a securities class action lawsuit is filed, our Case Evaluation Department reviews the allegations in the pleading and, operating with a degree of professional skepticism, seeks to independently verify each theory of liability. The analysis consists of reviewing: corporate filings with the Securities and Exchange Commission; corporate press releases; conference call transcripts; news articles; analyst reports; executive compensation figures; insider trading reports; and stock price movement (for the company being analyzed as well as the target company’s peers). We also analyze case law in the circuit where the action is pending, the opinions of the judge assigned to the case, and potential alternative forums for the action. After analyzing the relevant information, attorneys may consult with other departments within the Firm (such as the ERISA or Derivative Departments), forensic accountants and/or other experts to fully analyze the relevant issues and provide a comprehensive recommendation. Our Case Evaluation Department also has at its disposal an internal Investigative Services Department with six (6) fulltime investigators led by a former Special Agent with the Federal Bureau of Investigation. Our Investigative Services Department regularly assists our attorneys with developing facts supporting theories of liability (either pled in the complaint or developed by our analysis). We generally employ the same methodology for evaluating potential actions abroad. Where an action has a non-U.S. component, and after assessing the merits of the case, if warranted, we consult with attorneys in non-U.S. jurisdictions to determine whether our factual analysis supports claims under the laws of the non-U.S. jurisdiction. As evidenced by the number of non-U.S. actions the Firm is currently involved in (e.g., Fortis Bank, Olympus, RBS, Sino-Forest, Agnico Mining Corp., Vivendi), our working relationships with counsel in countries outside the United States has been of particular benefit to the Firm in light of the Morrison decision. Following our investigation, we prepare a comprehensive memorandum summarizing the relevant facts of the case, explaining our theory of liability, and analyzing the strengths and weaknesses of every potential claim. This memorandum will analyze arguments likely to be raised by the defendants, and includes our assessment of the merits of such arguments. Our analysis strives to provide the client with all of the necessary facts and legal authority to sufficiently weigh the risks and benefits of actively pursuing (or remaining passive in) an action. Attached as “Exhibit B” please find a sample client research memorandum. Our clients receive this level of detailed reporting in any instance in which the Firm recommends active participation in a shareholder action. Although we review every U.S. securities class action filed, along with a number of actions filed overseas, we again emphasize that we are highly selective in cases we recommend that a client seek lead or representative status. The Firm only advises clients to seek appointment as lead plaintiff, named plaintiff, or otherwise become actively involved, in cases where our analysis reveals a compelling case of fraud, with significant damages and viable sources of recovery. Where any of the foregoing factors are absent, we recommend that our clients remain passive class members. Even when we advise clients to remain passive, we continuously assess developments and will revisit our recommendation should 10 new facts warrant a different course of action. We strive to ensure that any case we bring to a client to consider will be a significant action worthy of leadership by a committed institutional investor. The following points highlight and summarize what we believe make us especially suited to serve the Fund: • Kessler Topaz has expertise litigating an extremely wide variety of cases in the securities class action, direct action, derivative, and merger/acquisition arenas and, in the process, serves a significant number of large, sophisticated institutional investors with varied interests. We are one of very few firms in the field that has equally robust securities, derivative and mergers/acquisition practices and that has a truly international practice litigating cases in non-U.S. jurisdictions. • The Firm’s size, resources and capitalization enable it to litigate a case of any magnitude through trial. We have sufficient personnel and resources to litigate against any defense firm in the country. Nevertheless, we stress selectivity in recommending cases that our clients pursue. • In November 2014, after the Firm took only the 24th securities class action to trial since 1996, an eight-person New York federal jury entered a verdict holding former Longtop Financial Technologies CFO Derek Palaschuk liable for the company’s alleged misrepresentations about its financial condition – this, after a default judgment order was entered against the company in 2013 which included a damages award of $882.3 million. In 2011, after a week-long trial, Kessler Topaz achieved the largest award of damages in a shareholder derivative case ever ordered in the Delaware Court of Chancery, a $2 billion award on behalf of Southern Peru Copper Corporation. Additionally, in February/March 2015, the Firm concluded another trial in the Delaware Court of Chancery in a stockholder action on behalf of former Dole Foods Co., Inc. shareholders. Following this nine day trial, Kessler Topaz won a $148 million verdict -- representing the second-largest post-trial verdict ever in merger litigation, behind only the Firm’s landmark $2 billion verdict in Southern Peru. Finally, in 2010 after over a month of trial, Kessler Topaz received an initial, favorable verdict from a jury in a case against BankAtlantic Bancorp, Inc. in Federal Court in Miami, Florida. Defendants know we are willing to take a case the distance. • Kessler Topaz takes an aggressive, yet deliberate, approach to litigation. While our clients’ interests are always our primary concern, we remain keenly aware of the need to ensure, whenever possible, that the companies we pursue are in better shape going forward than they were at the start of litigation. • Kessler Topaz takes great pride in the relationships we have developed and continue to develop with our clients. Regardless of whether the client has a pension fund with $10 million in assets or more than $1 trillion in assets, all of our clients receive the same high level of personal service. • We only advise clients to seek lead plaintiff appointment in cases involving compelling instances of fraud, with significant damages and viable sources of recovery. • Kessler Topaz’s securities portfolio monitoring and claims administration client service program is the most comprehensive in the field -- covering both U.S. based and non-U.S. based shareholder litigation. 11 Portfolio Monitoring & Claims Administration Program Kessler Topaz’s portfolio monitoring and claims administration client service program was introduced in 2004, and has evolved into what we are confident is the most advanced and comprehensive service available. The Firm currently provides these services to more than 250 institutional investors worldwide and takes great pride in the fact that we conduct all work via our 19- member Portfolio Monitoring and Claims Administration Department. In light of the U.S. Supreme Court’s decision in Morrison v. National Australia Bank, the Firm has extended its portfolio monitoring service to include all non-U.S. securities actions involving securities purchased on a non-U.S. exchange which impact our clients’ portfolios. Securities Portfolio Monitoring Kessler Topaz attorneys and staff will work with the Fund to monitor, analyze, investigate and provide consultation regarding potential securities fraud, corporate mismanagement and any other fiduciary or shareholder issues as requested. We will work closely with the Fund’s staff to identify and consult on the potential rewards of serving as lead plaintiff versus remaining an absent class member, objecting to a proposed settlement, filing a direct/opt-out action, and filing a derivative action in state or federal court depending on the particular situation. More specifically, the portfolio monitoring program consists of the following: Securities Tracker Kessler Topaz, with the assistance of experts in the field, has developed a proprietary, secure, portfolio monitoring database system, which we have dubbed “Securities Tracker.” We will request from the Fund (or its custodial bank) a minimum five-year history (preferably ten-year history) of the Fund’s securities transactions that we will then integrate into Securities Tracker. This information is updated regularly, and we will work with you to ensure that the information is obtained efficiently and without cost to the Fund, and is maintained confidentially. Once this information is obtained, Securities Tracker enables us to identify any trades that are subject to a claim or securities action, which has been filed or settled. Also, this system, along with our analysts, enables us to quickly calculate financial losses for the Fund in a particular securities action. Reporting New Case Summaries: When it is determined that a claim exists, or a securities class action is filed, we research our database to identify any and all clients who have an investment that is impacted. Whenever a client suffers a financial loss (no matter the size of the loss), we automatically prepare for that client a brief, yet concise, report which details (i) the relevant facts and class period, (ii) the applicable jurisdiction(s), (iii) all relevant deadlines, including those for filing lead plaintiff motions, objecting to or opting out of proposed settlements and submitting proof of claim forms, and (iv) the strengths and weaknesses of the case. This report will include the estimated financial losses suffered by a client utilizing the first in first out methodology, as well as the estimated damages suffered by the class as a whole. Further, we will generally recommend a course of action for the client to maximize its recovery of losses. These reports are provided to the client regardless of the size of the loss suffered , something that makes our monitoring service unique in the field. Attached as “Exhibit C” please find a sample case summary from a recent securities class action. 12 If it is determined that a case has the right mix of facts and losses that warrant consideration by the Fund to take an active role, Kessler Topaz will provide an in-depth case research memorandum for review. Attached as “Exhibit B” please find a sample client research memorandum. Quarterly Reports: To remain current on all securities class actions of interest, we will prepare and distribute to the Fund a quarterly update report. This report is tailored specifically for each client so that it can review significant developments in cases that affect only their specific investments, including listings of all settled cases and the deadline for filing claims. These reports are generated for the benefit of all our clients, regardless of whether they are serving as representative plaintiffs. These reports further ensure that our clients are diligently fulfilling their fiduciary responsibilities to plan members by actively monitoring securities class actions in which they have a financial interest. In light of the Morrison decision, we have modified our reporting to include a separate section for all non-U.S. jurisdiction securities actions. Attached as “Exhibit D” please find a sample client quarterly report. Online Access: All clients have complete, secure (256-bit SSL Encryption), 24/7 online access (viewable by multiple people in an organization) to information necessary to properly monitor actions in which they: (i) serve as a plaintiff; (ii) have a financial interest; and/or (iii) have filed proof of claim forms in connection with settlements. A sample Securities Tracker client page, containing quarterly reports, case summaries, and settlement charts may be viewed on the Firm’s website: www.ktmc.com (click on the blue “Log In” button on the bottom right-hand corner of the homepage; Username: ABCEmployees Password: Asdf123456! then click on the blue “Log In” button. We would be happy to provide the Fund with an online tutorial upon request. Claims Administration Claims Filing The Firm understands that the recovery of money from class action settlements is extremely important to pension funds of all sizes. For all monitoring clients we offer to prepare and submit proof of claim forms on their behalf, prepare authority letters when necessary, and work directly with the claims administrators to resolve deficiencies and any other issues that may arise in the course of settlement administration. The Firm also files claims in non-U.S. jurisdiction case settlements -- something U.S.-based custodians are not in a position to do. This service is offered at no cost to the Fund and we do not take a percentage of moneys recovered from claims administration (something unique in the field). Importantly, we are flexible in adjusting this program to meet the needs of each client (for example, several clients have elected to have the Firms be responsible for submitting claims in non-U.S. actions while the client’s custodian maintains filing responsibility for U.S. claims) and have seen a growing number of clients take advantage of this aspect of our program as it provides a level of service that even paid services do not provide. Kessler Topaz currently files proofs of claim for over one-hundred (100) clients. From 2008- 2016, the Firm helped our clients recover over $270 million in securities class action settlement proceeds. The Firm’s Portfolio Monitoring and Claims Administration Department is focused solely on monitoring client investments and processing proofs of claim in settled actions, and is in weekly, if not daily, contact with over twenty (20) claims administrators around the country. Please refer to the sample settlement chart attached as “Exhibit E”. This chart is provided to all clients for whom the Firm is filing 13 proofs of claim, is updated bi-weekly and posted to the client’s online account, and provides a full listing of every settlement in which a client has a financial interest and an accounting of the settlement proceeds recovered on behalf of the client to date. The Firm’s claims administration client service program enables trustees to easily inventory the settled class actions impacting their portfolio and allows them to report back to their pensioners regarding how much money they have returned to their fund from securities litigation. Finally, this program enables trustees to fulfill their fiduciary duties to plan members by diligently protecting plan assets. Should the Fund ever decide to make a change from its current claims filing arrangement and have our Firm handle the claims administration process on its behalf, we are certain in our ability to ensure that every dollar entitled to the Fund’s pensioners from securities litigation settlements is returned properly. Claims Auditing Kessler Topaz provides a cost-free auditing service of custodial banks to ensure that claims are being filed correctly on behalf of our clients in securities class actions and that all sums owed to our clients are being properly collected. The Firm currently conducts audits of claim filings for over 30 clients. As the Fund already has an arrangement in place for handling the claims administration process through its custodian (or other third-party filer), the Firm will gladly assist as needed to protect the Fund’s interests as a member of the class. First, the Firm would ask that the Fund’s custodian be directed to provide us with a report of the claims it filed on the Fund’s behalf from January 2015 - present to take a snap-shot of their filing practices. We will then cross-check this information against what we would have filed to ensure that no claims were missed and use this information to provide us with a reasonable sample size to determine the service provider’s accuracy in claims filing. The Firm will then provide the Fund with an audit report outlining our findings and, to the extent any discrepancies are found, we will assist with the filing of any missed claims (the Firm will utilize our contacts with various claims administrators to see if it is possible to submit a late claim if necessary so that the Fund can participate in the settlement proceeds where entitled to do so). Attached as “Exhibit F” please find a sample claims audit report. We then ask going forward, that we are provided with monthly reports of all the claims filed on behalf of the Fund. We will again cross-check this information to ensure that no claims were missed and will assist with the filing of any missed claims as needed. Each quarter, the Fund will receive an update report from the Firm which will contain a summary of our auditing efforts. Investor Education Kessler Topaz is committed to institutional investor education. The Firm goes to great lengths to keep its clients abreast of all relevant developments in shareholder litigation impacting their investments. To that end, the Firm publishes/has published a quarterly newsletter and primer on shareholder litigation. 14 Kessler Topaz Bulletin The Kessler Topaz Bulletin is a quarterly newsletter which provides our clients, investors, and consumers with an overview of the shareholder litigation and corporate governance landscape. The Bulletin contains articles not only focused on cases the Firm is litigating, but also on a variety of trends and issues affecting institutional investors. Firm attorneys regularly contribute articles about the cases they are litigating, important legal precedents, and other issues relevant to our practice. Kessler Topaz Primer on Shareholder Litigation Kessler Topaz has published A Primer on Shareholder Litigation to explain the litigation options available to investors under U.S. federal and state securities laws. Kessler Topaz believes these laws should be viewed as tools that allow investors, among other things, an opportunity to recover investment losses suffered as a result of fraud or other illegal conduct and/or to implement corporate governance changes. Our Primer is intended to provide a thorough background on securities class actions, derivative actions, takeover actions, opt-outs and direct actions, serving as a lead plaintiff, and litigating an action. Kessler Topaz is also proud to have developed two annual conferences of our own (described below), bringing together public pension fund trustees, investment staff and fund counsel, as well as industry professionals and legislators, to focus on corporate governance, fiduciary obligations, and other issues pertinent to institutional investors. These seminars are a reflection of Kessler Topaz’s commitment to not only serving as legal counsel to its clients, but also to being an educator on all issues related to shareholder activism and asset protection and recovery. The Firm’s philosophy is that an educated client not only serves itself better, but with proper education, serves the interests of others as well. The Rights and Responsibilities of Institutional Investors (RRII) Since 2006, the RRII seminar, held each March in Amsterdam, Netherlands, is dedicated to educating investors about their rights and responsibilities with respect to their U.S. and global investments. This annual meeting provides a forum for leaders in the investment and legal community to explore the role that active ownership and shareholder rights can play in better serving their funds and their beneficiaries. Each year over 100 senior executives and legal and compliance professionals from public pension funds, mutual fund companies, hedge funds, insurance companies, and other institutional investors and their advisors from around the globe, come together to share experiences and learn more about approaches to active ownership and what they can do to protect and enhance their assets. Past keynote speakers have included 42nd President of the United States Bill Clinton, President Mikhail Gorbachev, Former Prime Minister Tony Blair, Vice President Al Gore, Sir Richard Branson, and United Nations Secretary General Kofi Annan. In addition, the agenda includes high level speakers from many of the world’s largest institutional investors and the academic community. The Evolving Fiduciary Obligations of Institutional Investors (EFOII) Since 2010, the EFOII seminar held each February in Washington, D.C., provides a comprehensive examination of many vital issues that the advisors of pension plans and other 15 institutional investors must understand in order to properly fulfill their roles. It offers objective viewpoints on how fiduciaries can best meet their goals and avoid problems, in addition to offering timely information and guidance on various legal alternatives available to resolve issues as they surface. Over the course of this one-day event, attendees hear from a variety of peers and outside experts who share their knowledge, experience, and expertise about the most critical issues facing plan sponsors, their legal counsel, and their boards. Past keynote speakers have included former U.S. Secretary of State and Chairman of the Joint Chiefs of Staff General Colin L. Powell, U.S. Secretary of State Madeleine K. Albright, former U.S. Representative Barney Frank, former U.S. Securities and Exchange Commission Chairman Richard Breeden, political/media personalities James Carville and Mary Matalin, as well as high level speakers from many of the nation’s largest institutional investors and the academic community. Educational Seminars Kessler Topaz also has a great deal of experience providing half-day and full-day seminars to legal and investment professionals on the topics of securities fraud and shareholder litigation. Over the past five years, the Firm has provided such seminars to public pension funds as well as private investors from the United States and Europe. Topics have included: -Class Action Case Development; -Portfolio Monitoring; -Morrison v. National Australia Bank and the Non-U.S. Jurisdiction Shareholder Litigation Landscape; -Being Appointed and Serving as a Lead Plaintiff; -Litigating a Securities Class Action; -Direct Actions and Opt-Outs; -Derivative and Takeover Litigation; -The Settlement Process and the Importance of Proper Claims Administration We would be happy to provide these seminars, complete with handout materials and full power- point presentations for each topic, at the Fund’s office or any other convenient location. Conclusion We are confident that Kessler Topaz has the skill, experience, resources and expertise to advise and represent the Fund on any securities litigation matter and look forward to developing a long term relationship that will significantly benefit you and your pensioners. Please do not hesitate to contact us with any questions you may have or for any additional information you may require. EXHIBIT A KESSLER TOPAZ’S INSTITUTIONAL INVESTOR CLIENT LIST U.S. PUBLIC PENSION FUND CLIENTS Alameda County Employees’ Retirement Association Alaska Permanent Fund Corporation Arizona State Retirement System Arkansas Public Employees Retirement System Arkansas Teacher Retirement System Beaver County Employees’ Retirement Fund Bonita Springs Fire Control and Rescue District Firefighters’ Retirement System Brockton Retirement Board Bucks County Retirement Board Butler County Retirement Board California State Teachers’ Retirement System (CalSTRS) Cambria County Employees Retirement System Carbon County Employees Retirement Board Chester County Employees’ Retirement Fund City of Alpharetta Defined Benefit Pension Plan City of Austin Police Retirement System City of Avon Park Firefighters’ Retirement System City of Bethlehem Retirement System City of Bridgeport Retirement System City of Brookville Firefighters Retirement Trust Fund City of Boynton Beach General Employees’ Pension Fund City of Cape Coral Municipal Firefighters’ Retirement Plan City of Cape Coral Municipal General Employees’ Pension Trust Fund City of Coral Springs Firefighters’ Retirement Plan City of Coral Springs Police Officers’ Retirement Plan City of Dade City Municipal Firefighters’ Pension Trust Fund City of Dade City Municipal Police Officers’ Pension Trust Fund City of Daytona Beach Police and Fire Pension Fund City of Deerfield Beach Municipal Firefighters’ Pension Trust Fund City of Deltona Firefighters’ Pension Plan City of Englewood Florida Firefighters’ Pension Trust Fund City of Fort Lauderdale General Employees’ Retirement System City of Fort Meade Pension Trust Funds City of Fort Myers General Employees’ Pension Fund City of Fort Myers Police Officers’ Retirement System City of Hartford Municipal Employees’ Retirement Fund City of Kanas City Missouri Firefighters’ Pension Trust System City of Key West General Employees’ Pension Fund City of Knoxville Employees’ Pension System KESSLER TOPAZ’S INSTITUTIONAL INVESTOR CLIENT LIST City of Leesburg Municipal Police Officers’ Pension Trust Fund City of Leesburg Retirement Plan for General Employees’ City of Marietta/BLW Defined Benefit Pension Plan City of Miami Fire Fighters’ and Police Officers’ Retirement Trust City of Miami Fire Fighters’ Relief & Pension Fund City of Oakland Municipal Employees’ Retirement System City of Oakland Police and Fire Retirement System City of Ocoee Municipal Police Officers and Firefighters Retirement Trust Fund City of Orlando Firefighters’ Pension Fund City of Orlando General Employees’ Pension Fund City of Orlando Police Pension Fund City of Palm Beach Gardens Police Officers’ Pension Fund City of Philadelphia Board of Pensions & Retirement City of Phoenix Employees’ Retirement System City of Pittsburgh Comprehensive Municipal Pension Trust Fund City of Pompano Beach General Employees’ Retirement System City of Providence City of Sanford Firefighters’ Retirement System City of San Jose 1975 Federated City Employees’ Retirement System City of San Jose 1961 Police and Fire Department Retirement Plan City of Seminole Municipal Firefighters’ Pension Trust Fund City of St. Cloud General Employees’ Retirement System City of St. Cloud Police Officers’ and Firefighters’ Retirement System City of Sunrise Firefighters’ Retirement Fund City of Sunrise General Employees Pension Plan City of Tallahassee Pension Plan City of Tarpon Springs Municipal Firefighters’ Pension Trust Fund City of Titusville General Employees’ Pension Plan City of Titusville Police Officers’ and Firefighters’ Pension Plan City of Wilmington City Pension Fund for Firefighters and Police Officers in the City of Pembroke Pines Clayton County, Georgia Public Employee Retirement System Colorado Public Employees Retirement Association Commonwealth of Pennsylvania State Employees’ Retirement System Connecticut Retirement Plans & Trust Funds Cumberland County Retirement Fund Dauphin County Retirement Board District of Columbia Retirement Board Employee Retirement System of Rhode Island and the State Investment Commission Erie County Employees Retirement System Fire and Police Pension Association of Colorado KESSLER TOPAZ’S INSTITUTIONAL INVESTOR CLIENT LIST Firefighters Pension and Relief Fund for City of New Orleans Fort Worth Employees’ Retirement Fund Franklin County Employees Retirement Fund Georgia Firefighters’ Pension Fund Harrisburg Police Pension Board Imperial County Employees’ Retirement System Iowa Public Employees’ Retirement System Judges of the Probate Courts Retirement Fund of Georgia Kern County Employees’ Retirement Association Key West Police and Fire Pension Board of Trustees Lackawanna County Employees’ Retirement Fund Lancaster County Employees Retirement Fund Lawrence County Employees’ Retirement Board Lebanon County Employees’ Retirement Fund Lehigh County Employees Retirement Fund Los Angeles County Employees’ Retirement Association Los Angeles Fire and Police Pension System (LAFPP) Los Angeles Water & Power Employees’ Retirement Disability & Death Benefit Plan Louisiana Municipal Police Employees Retirement System Luzerne County Retirement System Lycoming County Employees’ Retirement System Maine Public Employees Retirement System Maryland State Retirement & Pension Plan Memphis Light, Gas & Water Division Retirement and Pension System Mercer County Employees’ Retirement System Miami Beach Employees’ Retirement Plan Montgomery County Employees’ Retirement System New Orleans Harbor Police Retirement System New York State Common Retirement Fund Northampton County Employees Retirement Fund North Carolina Retirement Systems Northumberland County Retirement System Odessa Firefighters’ Relief and Retirement Fund Ohio State Retirement Systems Oklahoma Firefighters Pension & Retirement System Oklahoma Police Pension & Retirement System Oklahoma School Land Commission Oviedo Firefighter’s Pension Trust Fund Palm Harbor Special Fire Control & Rescue District Firefighters’ Pension Plan Pattonville Fire Protection District Defined Benefit Pension Plan Pennsylvania Public School Employees’ Retirement System KESSLER TOPAZ’S INSTITUTIONAL INVESTOR CLIENT LIST Pennsylvania Turnpike Commission Plymouth County Retirement Association Public Employees’ Retirement System of Mississippi Retirement Board of Allegheny County Riviera Beach Municipal Firefighters’ Pension Trust Fund Sacramento County Employees’ Retirement System San Diego City Employees’ Retirement System San Francisco City and County Employees Retirement System SEPTA (Southeastern Pennsylvania Transportation Authority) St. Lucie County Fire District Firefighters’ Pension Trust Fund St. Lucie County Fire District General Employees Retirement Plan Sheriffs’ Retirement Fund of Georgia South Miami Pension Plan State of Alaska Department of Revenue (Treasury Division) State of Michigan Retirement System State of New Jersey and its Division of Investment State of Oregon The Employees’ Pension Plan of the City of Clearwater, Florida The Firemen’s Retirement Fund of St. Louis The Sewerage and Water Board of New Orleans The University of Tennessee Town of Longboat Key General Employees’ Retirement System Town of Longboat Key Police Officers’ Retirement System U.S. Army Non-Appropriated Fund Employee Retirement Plan Vermont State Retirement System Virginia Retirement System Washington State Investment Board Westmoreland County Employees Retirement Fund Wilkes-Barre Aggregated Pension Trust Fund Winter Haven Firefighters’ Retirement System Winter Haven Police Officers’ Retirement System Worcester Retirement System York County Retirement Board INTERNATIONAL PUBLIC PENSION FUND CLIENTS AFA Livforsakringsaktiebolag Alecta pensionsförsäkring, ömsesidigt AMF Pension AP1 – First Swedish National Pension Fund AP4 – Fourth Swedish National Pension Fund AP7 – Seventh Swedish National Pension Fund KESSLER TOPAZ’S INSTITUTIONAL INVESTOR CLIENT LIST ATP - Arbejdsmarkedets Tillaegspension Arkitekternes PensionsKasse CARE Super Christian Super Czech National Bank Folksam Mutual Life Insurance Healthcare Employees’ Pension Plan – Manitoba Industriens Pension A/S Irish National Pension Reserve Fund KP Pension National University of Ireland, Galway Nottinghamshire County Council, Local Authority Pension Fund PenSam Invest (Nykredit) PenSam Liv forsikringsaktieselskab Pensionskassen for Jordbrugsakademikere og Dyrlaeger Pensioenfonds Vervoer PFA Pension PGGM Vermogensbeheer B.V. PKA Pension Funds Administration Ltd. SamPension KP Livforsikring A/S Stichting Philips Pensioenfonds Unipension Fondsmaeglerselskab A/S Universities Superannuation Scheme Varma Mutual Pension Insurance Company U.S. TAFT-HARTLEY FUND AND PRIVATE INSTITUTIONAL INVESTOR CLIENTS 1199SEIU Benefit and Pension Funds Amalgamated Bank American Federation of Musicians and Employers Pension Fund American Federation of Television & Radio Artists Health & Retirement Funds Ardsley Partners, L.P. Blasters, Drillrunners and Miners Union Local 29 Benefit Funds Buffalo Laborers Cement Masons and Plasterers Joint Pension Trust (Local 797) Cleveland Bakers and Teamsters Benefit Plans Construction Industry and Laborers Joint Pension Fund (Local 872) Delaware Investments Denver Area Meat Cutters and Employers Pension Plan Dimensional Fund Advisors LP Equity-League Pension & Health Trust Funds Hollow Metal Pension and Trust Funds KESSLER TOPAZ’S INSTITUTIONAL INVESTOR CLIENT LIST I.A.T.S.E., Local No. One Pension and Welfare Funds I.A.T.S.E. Local 720 (N.R.A.) Pension Trust Insulators Local 23 International Brotherhood of Boilermakers Local 154 International Brotherhood of Electrical Workers Local 26 International Brotherhood of Electrical Workers Local 143 International Brotherhood of Electrical Workers Local No. 163 Health and Welfare Fund International Brotherhood of Electrical Workers Local 212 Pension Fund International Brotherhood of Electrical Workers Local 237 International Brotherhood of Electrical Workers Local 357 International Brotherhood of Electrical Workers Local 380 International Brotherhood of Electrical Workers Local No. 445 Pension Fund International Brotherhood of Electrical Workers Local 607 International Union of Bricklayers and Allied Craftworkers Local #15 Pennsylvania International Union of Operating Engineers Local Union 94-94A-94B Iron Workers District Council, Philadelphia and Vicinity Pension Plan Iron Workers Local Union No. 405 Annuity Fund Iron Workers of Western Pennsylvania Benefit Plans Laborers District Council Construction Industry Laborers’ Local No. 130 Pension, Welfare and Annuity Funds Laborers Local No. 1174 Pension Fund League-ATPAM Pension Fund Logan Capital Management Massachusetts Laborers’ Benefit Funds Michigan Electrical Employees’ Pension Fund New York City District Council of Carpenters Pension and Welfare Funds NOITU (National Organization of Industrial Trade Unions) PA Local 47 Bricklayers and Allied Craftsmen Pension Plan Plasterers and Cement Masons Local No. 94 Pension Fund Plumbers & Pipefitters Local #51 Pension Fund Plumbers & Pipefitters Local No. 123 Plumbers & Pipefitters Local No. 520 Plumbers & Pipefitters Union Local 525 Pension Plan Plumbers and Steamfitters Local 373 Pension Funds Private Asset Management Rocky Mountain UFCW Unions & Employers Pension Plan Roofers Local Union No. 74-203 SEIU Building Service Local 32BJ Pension Plan SEIU Pension Plans Master Trust Sheet Metal Workers Local No. 9 Pension and Health Fund Sheet Metal Workers Local No. 40 Pension and Health Fund KESSLER TOPAZ’S INSTITUTIONAL INVESTOR CLIENT LIST Sheet Metal Workers Local 44 Shopmen Iron Workers Local Union 502 Susquehanna Laborers Teamsters Joint Council No. 53 Teamsters Local No. 142 Pension Trust Fund Teamsters Local 272 Labor-Management Pension Fund Teamsters Local 282 Trust Funds Teamsters Local No. 500 Severance Trust Fund Teamsters Local 639 – Employers Pension Fund Teamsters Local No. 813 & Affiliates Teamsters Local 837 Teamsters Local No. 945 The Local 804 I.B.T and Local 447 I.A.M. – UPS, Inc. Multi-Employer Retirement Plan Theriault Trust The Russell Investment Company Funds Washington State Plumbers & Pipefitters Industry Pension Plan Welfare & Pension Funds of UFCW Local 464A INTERNATIONAL PRIVATE INSTITUTIONAL INVESTOR CLIENTS Aberdeen Asset Management Allianz Global Investors Kapitalanlagegesellschgaft mbH AMF Fonder AB ANIMA SGR S. p. A. ARCA Fondi SGR S.p.A. Chou Associates Management, Inc. Danica Pension Danske Invest A/S DIP Hermes Investment Management Limited JOP Jyske Invest Kathrein & Co. Privatbank AG Maj Invest MN Services, N. V. Nordea Fund Management, filial af Nordea Funds Oy Finland Nordea Invest Funds S. A. (Luxembourg) Nordea Fonder AB (Sweden) Nordea Funds Ltd. Nordea Fondene Norge AS (Norway) PensionDanmark A/S EXHIBIT B   MEMORANDUM: PRIVILEGED ATTORNEY/CLIENT   COMMUNICATION AND ATTORNEY WORK PRODUCT  TO ABC Employees’ Retirement System  FROM Darren J. Check, Esquire  Sean M. Handler, Esquire  Naumon A. Amjed, Esquire  Ryan T. Degnan, Esquire    DATE February 28, 2016  RE Navient Corporation Securities   Litigation Client Research Memorandum  Approximate Losses Suffered by ABC Employees’ Retirement System: $30,613,212 (FIFO) $25,606,987 (LIFO) “[Navient’s] behavior is outrageous.” - Presidential Candidate and Former U.S. Secretary of State Hillary Clinton This memorandum analyzes claims under the federal securities laws against Navient Corporation (“Navient” or the “Company”)—the largest student loan servicer in the United States—and certain of its executive officers (the “Officer Defendants”) for, among other things, falsely touting the strength of Navient’s business prospects and student loan portfolios, understating Navient’s loan loss reserves, and concealing the fact that Navient and one of its debt collection subsidiaries was engaged in improper student loan servicing practices. The misleading nature of Defendants’ statements were revealed through a series of disclosures beginning on February 27, 2015 when it was announced that the U.S. Department of Education (“ED”) had elected to not renew its student debt collection contract with the Company’s Pioneer Credit Recovery (“Pioneer”) subsidiary. The ED’s decision was based on its discovery that Pioneer “made materially inaccurate representations to borrowers . . . at unacceptably high rates.” On this news, the price of Navient common stock declined $1.89 per share, or nearly 9%, from a close of $21.40 per share on February 27, 2015 to close at $19.51 per share on March 2, 2015. This single trading-day decline eliminated approximately $760 million from the Company’s market capitalization value. Concerns about Navient’s servicing practices also attracted scrutiny from the Consumer Fraud Protection Bureau (“CFPB”), and Navient admitted on August 24, 2015 that the CFPB was considering taking legal action against the Company for improper disclosures and assessments of late fees. In response, Navient common stock declined $1.85 per share, or approximately 13%, from a close of $13.89 per share on August 23, 2015, to close at $12.04 per share on August 25, 2015—eliminating more than $380 million from the Company’s market ii capitalization value. Then, on September 29, 2015, the CFPB issued a report discussing inappropriate servicing practices employed by several student loan servicers, including Navient. On this news, the price of Navient’s common stock declined $1.20 per share, or approximately 10%, from a close of $12.16 per share on September 28, 2015, to close at $10.96 per share on October 1, 2015. This three trading-day decline eliminated nearly $450 million from the Company’s market capitalization value. Additionally, fallout from Navient’s questionable servicing practices directly impacted the Company’s financial position as it was revealed on December 28, 2015 that the Federal Home Loan Bank of Des Moines was significantly reducing Navient’s available credit facilities, reportedly due to Congressional concern that government-sponsored banks should not be lending on favorable terms to student lenders that are not passing the savings on to borrowers. On this news, the price of Navient common stock declined $1.15 per share, or approximately 9%, from a close of $12.61 per share on December 24, 2015, to close at $11.46 per share on December 28, 2015. This decline eliminated an additional $415 million from the Company’s market capitalization value. During this time, Navient also belatedly acknowledged on July 13, 2015 that its Private Education Loan portfolio was significantly weaker than what the Company had previously touted. Specifically, Navient slashed its fiscal 2015 earnings guidance by more than 15% and significantly increased its loan loss provisions. In response, Navient stock price fell $1.94 per share, or approximately 11%, from a close of $18.36 per share on July 13, 2015, to close at $16.42 per share on July 14, 2015—eliminating $755 million from the Company’s market capitalization value. Finally, during a campaign stop in New Hampshire on February 6, 2016, Hillary Clinton called Navient’s behavior “outrageous” and noted that the Company has been “misleading people” and “doing some really terrible things.” In response, the price of Navient common stock declined $0.57 per share, or more than 6% from a close of $9.51 per share on February 5, 2016, to close at $8.94 per share on February 8, 2016. This decline eliminated another $205 million from the Company’s market capitalization value. Collectively, the corrective disclosures between February 27, 2015 and February 6, 2016 eliminated nearly $3 billion from Navient’s market capitalization value. To date, at least three class action lawsuits have been filed against Navient and certain of its executive officers (the “Officer Defendants”) in the United States District Court for the District of Delaware, alleging violations of Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) on behalf of all persons who purchased or otherwise acquired Navient securities between April 17, 2014 and February 5, 2016 (the “Class Period”).1                                                              1 The basis for this analysis comes from, inter alia, the allegations pled in: Menold v. Navient Corp., et al., No. 16-cv-00075 (D. Del. filed February 11, 2016); Jagrelius v. Navient Corp., et al., No. 16-cv-00084 (D. Del. filed February 12, 2016); and Policemen’s Annuity & Benefit Fund of Chicago v. Navient Corp., et al., No. 16-cv- TBD (D. Del filed February 26, 2016). Each action is currently pending before the Honorable Gregory M. Sleet. iii Additionally, claims under Sections 11, 12(a)(2), and 15 of the Securities Act of 1933 (the “Securities Act”) have been asserted against Navient, the Officer Defendants, certain of Navient’s directors, and certain underwriters of three Navient debt securities sold pursuant to offerings on November 5, 2015 and March 26, 2016 (the “Offerings”). 2 Based on ABC Employees’ Retirement System’s purchases of Navient common stock during the Class Period, we have estimated that ABC Employees’ Retirement System sustained a loss of approximately $30,613,212 under a first-in, first-out (“FIFO”) accounting basis and approximately $25,606,987 under a last-in, first-out (“LIFO”) accounting basis. We believe the claims against Defendants have substantial merit and that a portion of ABC Employees’ Retirement System’s loss may be recoverable under the federal securities laws. Accordingly, we recommend that ABC Employees’ Retirement System’s consider moving for appointment as lead plaintiff in the action. The deadline to seek appointment as lead plaintiff is April 11, 2016.                                                                                                                                                                                                    The Officer Defendants include: John F. Remondi (the Company’s President and Chief Executive Officer, and a Company Director); and Somsak Chivavibul (the Company’s Vice President and Chief Financial Officer). 2 Navient’s 5% Senior Notes due 2020 and 5.875% Senior Notes due 2024 were underwritten by Credit Suisse Securities (USA) LLC, Deutsche Bank Securities Inc., J.P. Morgan Securities LLC, RBC Capital Markets, LLC, Barclays Capital Inc., Goldman, Sachs & Co., Merrill Lynch, Pierce, Fenner & Smith Incorporated, and RBS Securities Inc. Navient’s 5.865% Senior Notes due 2021 were underwritten by Barclays Capital Inc., Credit Suisse Securities (USA) LLC, J.P. Morgan Securities LLC, Merrill Lynch, Pierce, Fenner & Smith Incorporated, Deutsche Bank Securities Inc., Goldman, Sachs & Co., RBC Capital Markets, LLC, and Wells Fargo Securities, LLC. iv TABLE OF CONTENTS FACTUAL BACKGROUND .............................................................................................................................. 1  I. The Company .................................................................................................................................... 1  II. Navient Touts Strength of Private Education Loan Portfolio and Servicing Practices  throughout the Class Period ............................................................................................................. 2  III. Navient Capitalizes on Positive Outlook; Sells $1.5 billion in Company Bonds ................................. 6  IV. Navient Slashes Guidance;  Significantly Increases Provisions for Loan Losses ................................ 6  V. Navient Comes Under Pressure from the ED, the CFPB, and Politicians .......................................... 7  LEGAL ANALYSIS ........................................................................................................................................... 9  I. Section 10(b) ................................................................................................................................... 10  A. Materiality and Falsity ...................................................................................................... 10  B. Scienter ............................................................................................................................. 14  C. Loss Causation .................................................................................................................. 16  II. Section 20(a) ................................................................................................................................... 17  III. Securities Act Claims ....................................................................................................................... 17  IV. ABC Employees' Retirement System ‐Specific Considerations ....................................................... 18  A. Potential Standing Challenges .......................................................................................... 18  B. ABC Employees' Retirement System’s Trading History and Recoverable Losses ............. 19  CONCLUSION .............................................................................................................................................. 19    1 FACTUAL BACKGROUND  I. The Company  Navient, a Delaware corporation headquartered in Wilmington, Delaware, is the largest student loan servicer in the United States. As of December 31, 2014, Navient serviced more than $300 billion in student loans held in its own portfolios and by third-party banks, credit unions, non-profit education lenders, and the U.S. Department of Education. Navient’s own student loan portfolios consisted of $29.8 in private education loans (the “Private Education Loan Portfolio”) and $104.5 billion in loans guaranteed under the Federal Family Education Loan Program (“FFELP”). Navient was formed in April 2014 through the spin-off of certain student loan portfolios and servicing operations from SLM Corporation (“Sallie Mae”). Navient began trading on the NASDAQ on a when-issued basis on April 17, 2014 and formally began trading on the NASDAQ under the ticker symbol “NAVI” on March 1, 2014.3 The Company’s market capitalization value reached a Class Period high of $9.3 billion on December 22, 2014, before falling to just $3.2 billion at the close of trading on February 8, 2016. The Company’s market capitalization value remains depressed and was $3.7 billion at the close of trading on February 24, 2016. The following chart illustrates the movement of the Company’s stock price on the NASDAQ over the Class Period:                                                              3 See SLM Corporation, Sallie Mae Board Approves Strategic Separation of Navient Corporation, Sets Record Date and Distribution Date, April 10, 2014, available at: http://news.salliemae.com/press-release/corporate- and-financial/sallie-mae-board-approves-strategic-separation-navient-corpora; Navient Corporation, Form S-1 filed April 22, 2014.   2 II. Navient Touts Strength of Private Education Loan Portfolio and Servicing Practices  throughout the Class Period  The Class Period begins on April 17, 2014 to coincide with the commencement of when- issued trading of Navient common stock, following the announcement of the Company’s spin-off from Sallie Mae. In connection with the spin-off, Navient and Sallie Mae filed a registration statement (the “Registration Statement”) with the SEC disclosing information regarding Navient’s operations and financial prospects.4 Among other things, the Registration Statement highlighted several of the Company’s “competitive advantages that will distinguish it from its competitors, including:”  Premier servicing market share and infrastructure well- positioned for evolving marketplace. . . . Navient’s premier market share and tested servicing and collections infrastructure make it well-positioned to expand its servicing and collections businesses to additional third-party FFELP, federal, private education and other loan portfolios.    Strong cash flow generation with ample debt service coverage. . . . Navient also expects it will be able to continue [Sallie Mae]’s policy of returning capital to stockholders through dividends and share repurchases, subject to limitations under a tax sharing agreement with [Sallie Mae].    Navient will have substantial institutional knowledge and expertise in student loan assets and finance markets.  Servicing platforms that offer substantial economies of scale. [Sallie Mae] has internally developed and purchased technology platforms, which will be owned by Navient. Navient will service and collect on DSLP loans for ED, on FFELP Loans for guarantor and other clients and on its own $103.2 billion portfolio of FFELP Loans and $31.0 billion portfolio of Private Education Loans (on a pro forma basis, as of December 31, 2013). These platforms are robust and scalable and will enable Navient to add additional accounts at low cost.5 The Registration Statement provided assurances to investors regarding the sufficiency of the Company’s loan loss provisions and declining delinquency rates in the Private Education Loan Portfolio:                                                              4 Navient Corporation, Form 10-12B/A filed April 14, 2014. 5 Id.   3  Provisions for Loan Losses Management estimates and maintains an allowance for loan losses at a level sufficient to cover charge-offs expected over the next two years.  Charge-Offs and Delinquencies When we conclude a loan is uncollectible, the unrecoverable portion of the loan is charged against the allowance for loan losses in the applicable segment. Charge-off data provides relevant information with respect to the performance of our loan portfolios. Management focuses on delinquencies as well as the progression of loans from early to late stage delinquency. The Consumer Lending segment’s charge-off rate was 2.8 percent of loans in repayment in 2013 compared with 3.4 percent of loans in repayment in 2012. Delinquencies are a very important indicator of potential future credit performance. Private Education Loan delinquencies as a percentage of Private Education Loans in repayment decreased from 9.3 percent at December 31, 2012 to 8.3 percent at December 31, 2013.6  In connection with Sallie Mae’s April 16, 2014 press release announcing its financial results for the first quarter 2014, Defendants further emphasized the strength of Navient’s Private Education Load Portfolio. Specifically, Defendant Remondi underscored that the “quarter set a six-year-record low in delinquencies, reflecting [Navient’s] strong underwriting and customer support.” 7 Additionally, the press release highlighted several credit metrics that improved in the first quarter 2014 versus first quarter 2013:  “Delinquencies of 90 days or more of 3.4 percent of loans in repayment [were] down from 3.9 percent.”  “Total delinquencies of 6.9 percent of loans in repayment [were] down from 7.8 percent.”  “Annualized charge-off rate of 2.8 percent of average loans in repayment [was] down from 3.0 percent.”  “Provision for private education loan losses of $175 million [was] down from $225 million.”8                                                               6 Id. 7 Navient Corporation, Form 8-K filed April 16, 2014. 8 Id. During the accompanying investor conference call held on April 17, 2014, Defendant Remondi further explained that the Company “saw 90 day delinquencies falls to 3.4% from 4.1% at year end and 3.9% a year ago. And as [Executive Vice President of Banking and Finance] Joe [DePaulo] said, charge-offs fell to an annualized rate at 2.8%. As a result, we were able to lower our provision for future loan losses to $175 million, down from $225 million in the year-ago quarter.” Q1 2014 SLM Corporation Earnings Conference Call – Final, FD (FAIR DISCLOSURE) WIRE, April 17, 2014.   4 Defendants also noted that the maximum additional capacity under the Company’s secured credit facilities continued to expand, and averaged $12.3 billion in first quarter 2014 versus $10.8 billion in the first quarter 2013. 9 On May 9, 2014, Navient filed its initial quarterly results (for the first quarter 2014) as a standalone company and reiterated the credit metrics for delinquencies, charge-offs, and loan loss provisions that had been previously provided to investors on April 16, 2014.10 Additionally, the Company affirmatively stated that it “believe[s] that the allowance for loan losses is appropriate to cover probable losses incurred in the loan portfolios.”11 Separately, Navient touted its “superior default prevention performance and industry leading asset recovery services” and claimed that “[f]ederal loan customers with loans serviced by Navient default at a rate 30 percent lower than the national average.”12 Furthermore, the Company assured investors that it “prides itself in a robust compliance culture driven by a ‘customer first’ approach.”13 In subsequent quarters, Navient continued to tout strong delinquency and charge-off metrics that were driving progressively declining loan loss provisions for the Company’s Private Education Loan Portfolio:   Delinquencies   (90+ Days) Delinquencies (Total) Annualized Charge‐ Off Rate  Loan Loss Provision  for Private Education  Loan Portfolio  First Quarter 201414 3.4% 6.9% 2.8% $175 million  Second Quarter 201415 3.2% 7.1% 2.5% $145 million  Third Quarter 201416 3.4% 7.9% 2.3% $130 million  Fourth Quarter 201417 3.8% 8.1% 2.5% $128 million  First Quarter 201518 3.6% 6.9% 2.9% $120 million                                                               9 Navient Corporation, Form 8-K filed April 16, 2014. 10 Navient Corporation, Form 8-K filed May 9, 2014. 11 Navient Corporation, Form 10-Q filed May 9, 2014. 12 Id. 13 Id. 14 See Navient Corporation, Form 8-K filed April 16, 2014; Navient Corporation, Form 8-K filed May 9, 2014. 15 See Navient Corporation, Form 8-K filed July 16, 2014. 16 See Navient Corporation, Form 8-K filed October 15, 2014. 17 See Navient Corporation, Form 8-K filed January 21, 2015. 18 See Navient Corporation, Form 8-K filed April 21, 2015.   5 To this end, Defendants repeatedly referenced improvements in the student lending environment. For example, in connection with the release of the Company’s second quarter 2014 financial results on July 16, 2014, Navient emphasized the “continued improvement in student loan portfolio credit quality” while Defendant Remondi explained that the Company’s “approach to loan servicing continues to help more customers successfully manage their student loan payments and avoid the consequences of default, as reflected in the improving credit quality of the loans we service.”19 Defendants made similar statement regarding improving credit conditions and the strength of the Company’s servicing practices when reporting Navient’s third quarter 2014, fourth quarter 2014, and first quarter 2015 financial results:  Third quarter 2014: “This quarter again demonstrated improved credit performance” as Navient saw “continued improvements in delinquencies and defaults since a year ago.”20  Fourth quarter 2014: “We continued to meet our commitment to create shareholder value as we . . . realized year-over-year improvements in credit quality.”21  First quarter 2015: “On the credit front, we continue to see delinquency rates and our outlook for future expected charge-offs on our private portfolio improve. . . . More importantly, for the federal loans we service, we continue to see significant improvement in recent graduates’ ability to successfully manage their loans. For example, the class of 2014, which recently entered repayment, is showing the best performance of any recent graduating class.”22                                                               19 Navient Corporation, Form 8-K filed July 16, 2014; see also 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, July 17, 2014 (“Our private loan segment continues to benefit from improving credit metrics, delinquencies and defaults continue to fall hitting six year lows, and driving down credit costs. Our loan servicing associates work closely with borrowers to find repayment solutions that not only keep borrowers out of default, but help them make real progress in repaying their debt balances.”). 20 Navient Corporation, Form 8-K filed October 15, 2014; see also Q3 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, October 16, 2014 (“Credit performance also continues to improve. Our repayment programs, along with an improving economy and increased portfolio seasoning, are all contributing to a strong and improving outlook.”). 21 Navient Corporation, Form 8-K filed January 21, 2015; see also Q4 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, January 22, 2015 (“The improving economy and growth in employment to young workers is helping student loan performance. We also see borrowers making better decisions, allowing them to successfully manage their student loan payments. The fact is that nationally, delinquencies and defaults are declining, and Navient is leading the way with more customers enrolled in affordable repayment programs, and dramatically lower default rates, compared to the national average.”). 22 Q1 2015 Navient Corp Earnings Call - Final, FD (FAIR DISCLOSURE) WIRE, April 22, 2015; see also Navient Corporation, Form 8-K filed April 21, 2015 (“We’re pleased to begin our first full year as Navient by helping more recent college graduates successfully transition into repayment. ”); id. (“Private credit quality also continued to improve, leading to a lower loan loss provision.”).   6 Against the backdrop of the purportedly improving credit climate, Defendants informed investors during Navient’s January 22, 2015 conference call that the Company anticipated “core” earnings per share of $2.20 in 2015.23 On April 22, 2015, Defendant Remondi confirmed that he “continue[s] to remain confident in [Navient’s] ability to generate core earnings per share of $2.20 for the year and [Navient’s] ability to lead the industry in helping customers successfully manage their loans and to execute on [its] growth initiatives.”24 III. Navient Capitalizes on Positive Outlook; Sells $1.5 billion in Company Bonds  Seeking to capitalize on the positive outlook surrounding the Company and its credit metrics, Navient sold $1.5 billion in senior notes to investors through public offerings during the Class Period. First, on November 5, 2014, Navient conducted a public offering of $500 million in 5% Senior Notes due 2020 and $500 million in 5.875% Senior Notes due 2024—generating more than $982 million in proceeds post-underwriting discounts.25 Then, on March 26, 2015, Navient conducted a public offering of $500 million in 5.875% Senior Notes due 2021— generating more than $492 million in proceeds post-underwriting discounts. 26 IV. Navient Slashes Guidance;  Significantly Increases Provisions for Loan Losses  Notwithstanding Defendants’ repeated assurances regarding improving credit conditions and the Company’s ability to help students manage their loan payments, Navient preannounced second quarter 2015 financial results on July 13, 2015 that fell well below its prior guidance.27 Specifically, Navient announced that it was cutting 2015 core earnings guidance from $2.20 per share to just $1.85 per share—a reduction of nearly 16%.28 According to the Company, the reduction was the result of, among other things, unfavorable credit trends in its Private Education Loan Portfolio. Navient explained that “[w]hile the majority of the private loan portfolio continues to perform as expected and is experiencing positive credit trends, a segment of higher risk private education loan borrowers who returned to school during the recession deferred repayment on their existing loans and exited deferment status in 2014 [and] [t]hese loans are experiencing unfavorable credit trends                                                              23 Q4 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, January 22, 2015. “Core” earnings excludes certain items including expenses in connection with Navient’s spin-off from Sallie Mae and unrealized gains and losses caused my mark-to-market valuations of derivatives. See Navient Corporation, Form 8- K filed January 21, 2015. 24 Q1 2015 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, April 22, 2015. 25 See Navient Corporation, Form 424b2 filed November 5, 2014. The 5% Senior Notes due 2020 and the 5.875% Senior Notes due 2024 were underwritten by Credit Suisse Securities (USA) LLC, Deutsche Bank Securities Inc., J.P. Morgan Securities LLC, RBC Capital Markets, LLC, Barclays Capital Inc., Goldman, Sachs & Co., Merrill Lynch, Pierce, Fenner & Smith Incorporated, and RBS Securities Inc. 26 See Navient Corporation, Form 424b2 filed March 26, 2015. The 5.865% Senior Notes due 2021 were underwritten by Barclays Capital Inc., Credit Suisse Securities (USA) LLC, J.P. Morgan Securities LLC, Merrill Lynch, Pierce, Fenner & Smith Incorporated, Deutsche Bank Securities Inc., Goldman, Sachs & Co., RBC Capital Markets, LLC, and Wells Fargo Securities, LLC. 27 See Navient Corporation, Form 8-K filed July 13, 2015. 28 See id.   7 compared to loans that exited deferment in prior years.”29 Given these credit trends, Navient was forced to “increase[] its provision for these loans and now projects a private education loan loss provision of $191 million for the quarter and $575 to $600 million for the year”—a 59% increase from the first quarter 2015 loan loss provision of $120 million.30 In response to the Company’s announcements, analysts from Barclays, Janney, Credit Suisse, and Buckingham all cut their stock price targets on Navient.31 On this news, the price of Navient common stock declined $1.94 per share, or approximately 11%, from a close of $18.36 per share on July 13, 2015, to close at $16.42 per share on July 14, 2015. This single trading-day decline eliminated approximately $755 million from the Company’s market capitalization value. V. Navient Comes Under Pressure from the ED, the CFPB, and Politicians  Questions surrounding the propriety of Navient’s student loan servicing practices began to surface on February 27, 2015 when the ED announced that it was not renewing its student loan debt collection contract with Navient’s Pioneer subsidiary after the ED discovered that Pioneer and four other private collection agencies “were providing inaccurate information to borrowers.”32 Specifically, the ED found that Pioneer “ha[d] given inaccurate information at unacceptably high rates about [loan rehabilitation] benefits [and] gave borrowers misleading information about the benefits to the borrowers’ credit report and about the waiver of certain collection fees.”33 Navient also disclosed in its 2014 Annual Report filed that same day that, in November 2014, Pioneer “received a [Civil Investigative Demand (“CID”)] from the CFPB as part of the CFPB’s investigation into Pioneer’s activities relating to rehabilitation loans and collection of defaulted student debt.”34 Moreover, Navient disclosed that it had “received a subpoena from the New York Department of Financial Services [(the “NY DFS”)]” in December 2014.35 These investigations followed a previously disclosed CID from the CFPB “regarding allegations relating to Navient’s disclosures and assessment of late fees and other matters.”36                                                              29 Id. 30 Id. 31 See Barclays Capital Inc., Disappointing Guidance, but Sell-off Overdone; Upgrading to Overweight, July 15, 2015; Janney Montgomery Scott LLC, NAVI’s 2Q Earnings Pre-announcement Disappoints; Lowering Estimates, July 14, 2015; Credit Suisse Securities, Lowers’15 Guidance on Higher Interest Exp and Provision, July 13, 2015; Buckingham Research Group, Lowering Estimates Following 2Q Preannouncement, July 14, 2015. 32 U.S. Department of Education, U.S. Department of Education to End Contracts with Several Private Collection Agencies, February 27, 2015, available at: http://www.ed.gov/news/press-releases/us-department- education-end-contracts-several-private-collection-agencies. 33 Id. 34 Navient Corporation, Form 10-K filed February 27, 2015; see also id. (“Since 1997, Navient has provided asset recovery services on defaulted student loans to ED. This contract expired by its terms on February 21, 2015 and our Pioneer Credit Recovery subsidiary received no new account placements under the contract.”). 35 Id. 36 Id.   8 Analysts expressed significant concern regarding the regulatory action and the looming investigations into the Company’s practices. Barclays, for example, downgraded the Company on the news and noted that “The Loss of the Department of Ed Collections Contract along with Potential Regulatory Risk Stemming from the CIDs issued by the CFPB and Several State AGs as well a Subpoena from the NY DFS around [Navient]’s Collections Business make Risk/Reward Unattractive at These Levels[.]”37 Similarly, analysts from Janney lowered their 2015 and 2016 earnings estimates for Navient in response to what they called “A Negative Surprise.”38 In response, Navient’s common stock declined $1.89 per share, or nearly 9%, from a close of $21.40 per share on February 27, 2015 to close at $19.51 per share on March 2, 2015. This single trading-day decline eliminated approximately $760 million from the Company’s market capitalization value. On August 24, 2015, Navient announced that it had “received a letter from the CFPB [on August 19, 2015] notifying [the Company] that . . . the CFPB’s Office of Enforcement is considering recommending that the CFPB take legal action against [Navient]” in connection with the “previously disclosed investigation into [Navient]’s disclosures and assessment of late fees.”39 Navient’s stock price responded by falling $1.85 per share, or approximately 13% from a close of $13.89 per share on August 23, 2015, to close at $12.04 per share on August 25, 2015. This two trading-day decline eliminated more than $380 million from the Company’s market capitalization value. Then, on September 29, 2015, the CFPB issued a report discussing inappropriate practices employed by several student loan servicers, including Navient.40 As noted by The Wall Street Journal, “[a]mong the biggest issues being raised by the CFPB is that some servicers aren’t providing struggling borrowers with adequate information about affordable repayment options—in particular income-driven repayment plans—and those borrowers can end up in default as a result.”41 Similarly, The Washington Post explained that the CFPB’s “blistering report” concluded that “[t]he sloppy, haphazard work of student loan servicers, the middlemen who collect and apply payments, is creating obstacles to repayment, raising costs and driving borrowers into default.”42 On this news, the price of Navient common stock declined $1.20 per share, or approximately 10%, from a close of $12.16 per share on September 28, 2015, to close at $10.96                                                              37 Barclays Capital Inc., Risk/Reward No Longer Attractive; Downgrading to Equal Weight, March 2, 2015. 38 Janney Montgomery Scott LLC, Navient Loses DoE’s Student Loan Collections Contract - A Negative Surprise, March 2, 2015. 39 Navient Corporation, Form 8-K filed August 24, 2015. 40 See Consumer Financial Protection Bureau, Student Loan Servicing: Analysis of Public Input and Recommendations for Reform, September 29, 2015, available at: http://files.consumerfinance.gov/f/201509_cfpb_student-loan-servicing-report.pdf. 41 Annamarie Andriotis, Consumer Regulator Hits the Books on Student-Loan Problems, THE WALL STREET JOURNAL, September 29, 2015. 42 Danielle Douglas-Gabriel, The Surprisingly High Number of People Who Are Behind on Their Student Loans, THE WASHINGTON POST, September 29, 2015.   9 per share on October 1, 2015. This three trading-day decline eliminated an additional $450 million from the Company’s market capitalization value. Navient’s dubious servicing practices also directly impacted the Company’s financial position. On December 28, 2015, Navient informed investors that the Federal Home Loan Bank of Des Moines (“FHLB-DM”) was significantly reducing Navient’s maximum borrowing capacity under its credit facilities with the FHLB-DM from $10.7 billion (as of December 1, 2015) to $5.0 billion (between December 22, 2015 and October 31, 2016)43 and to $3.9 billion (after October 31, 2016). While Navient explained that it “believes this change was made due to an internal policy change in the formula the FHLB-DM uses to set a borrower’s maximum borrowing limit,” the FHLB-DM’s decision followed U.S. Senator Elizabeth Warren’s demands to know why a government-sponsored bank was lending on favorable terms to student lenders that are not passing the savings on to borrowers.44 On this news, the price of Navient common stock declined $1.15 per share, or approximately 9%, from a close of $12.61 per share on December 24, 2015, to close at $11.46 per share on December 28, 2015. This single trading-day decline eliminated an additional $415 million from the Company’s market capitalization value. Navient’s conduct also drew the ire of presidential-hopeful and former U.S. Secretary of State Hillary Clinton. During a town hall campaign event in New Hampshire on February 6, 2016, Secretary Clinton told the audience that Navient’s “behavior is outrageous” and that she was “totally appalled” by the Company’s actions. Secretary Clinton further remarked that Navient has been “misleading” borrowers and has been “doing some really terrible things.”45 The price of Navient common stock declined $0.57 per share, or more than 6%, in response to Secretary Clinton’s comments, falling from a close of $9.51 per share on February 5, 2016, to close at $8.94 per share on February 8, 2016. This decline eliminated another $205 million from the Company’s market capitalization value. LEGAL ANALYSIS  The foregoing facts, supported by our ongoing investigation, may be sufficient to plead claims under Sections 10(b) and 20(a) of the Exchange Act against Navient and the Officer Defendants. These facts may also be sufficient to plead claims against Navient, the Officer Defendants, certain of Navient directors, and certain underwriters under Sections 11, 12(a)(2), and 15 of the Securities Act in connection with Navient debt securities sold pursuant to the Offerings.                                                              43 Navient Corporation, Form 8-K filed December 28, 2015. 44 Id.; see also Shahien Nasiripour, How Elizabeth Warren Beat a Student Loan Giant, THE HUFFINGTON POST, December 31, 2015. 45 See Shahien Nasiripour, Hillary Clinton ‘Totally Appalled’ by Student Loan Giant Navient, THE HUFFINGTON POST, February 7, 2016; Amanda Becker, Clinton Slams Student Loan Servicer Navient as Misleading, Reuters, February 8, 2016; Jennifer Epstein, Clinton: Student Loan Servicer Navient ‘Misleading People’, Bloomberg, February 6, 2016.   10 I. Section 10(b)   In order to plead a claim under Section 10(b) of the Exchange Act, which prohibits fraud or deceit in connection with the purchase or sale of securities, plaintiffs must establish: “(1) a material misrepresentation (or omission); (2) scienter, i.e., a wrongful state of mind; (3) a connection with the purchase or sale of a security; (4) reliance, often referred to in cases involving public securities markets (fraud-on-the-market cases) as ‘transaction causation;’ (5) economic loss; and (6) ‘loss causation,’ i.e., a causal connection between the material misrepresentation and the loss.” Dura Pharmaceuticals, Inc. v. Broudo, 544 U.S. 336, 341 (2005) (citations omitted). A. Materiality and Falsity  False statements or omissions form the basis of liability under Section 10(b) only if they are material. Information is material if there is a “substantial likelihood [that] the disclosure of the [omitted] fact would have been viewed by the reasonable [investor] as having significantly altered the ‘total mix’ of information made available.” Opengate Capital Group LLC v. Thermo Fisher Sci. Inc., 2014 U.S. Dist. LEXIS 92256 (D. Del. July 8, 2014) (Sleet, J.) (quoting Basic Inc. v. Levinson, 485 U.S. 224, 231-32 (1988)). Here, the following general categories of omissions and statements would form the basis of investors’ claims under Section 10(b):  Defendants’ representations regarding the health of the Company’s Private Education Loan Portfolio and credit metrics;46  Defendants’ representations regarding the sufficiency of the Company’s provisions for loan losses;47                                                              46 See, e.g., Navient Corporation, Form 8-K filed July 16, 2014 (“continued improvement in student loan portfolio credit quality”); id. (“approach to loan servicing continues to help more customers successfully manage their student loan payments and avoid the consequences of default, as reflected in the improving credit quality of the loans we service”); 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, July 17, 2014 (“Our private loan segment continues to benefit from improving credit metrics, delinquencies and defaults continue to fall hitting six year lows, and driving down credit costs.”); Q3 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, October 16, 2014 (“Credit performance also continues to improve. Our repayment programs, along with an improving economy and increased portfolio seasoning, are all contributing to a strong and improving outlook.”); Q4 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, January 22, 2015 (“The improving economy and growth in employment to young workers is helping student loan performance. We also see borrowers making better decisions, allowing them to successfully manage their student loan payments.”); Q1 2015 Navient Corp Earnings Call - Final, FD (FAIR DISCLOSURE) WIRE, April 22, 2015 (“More importantly, for the federal loans we service, we continue to see significant improvement in recent graduates’ ability to successfully manage their loans. For example, the class of 2014, which recently entered repayment, is showing the best performance of any recent graduating class.”). 47 See, e.g., Navient Corporation, Form 10-Q filed May 9, 2014 ( “the allowance for loan losses is appropriate to cover probable losses incurred in the loan portfolios”); Navient Corporation, Form 10-Q filed August 1, 2014 (same); Navient Corporation, Form 10-Q filed October 30, 2014 (same); Navient Corporation, Form 10-K filed February 27, 2015 (same); Navient Corporation, Form 10-Q filed April 30, 2015 (same).   11  The Company’s 2015 core earnings guidance;48 and  Defendants’ representations regarding the Company’s commitment to compliance and proper servicing practices.49  Navient’s Private Education Loan Portfolio, Loan Loss Provisions, and Core Earnings Guidance  Defendants’ repeated representations regarding the health of the Company’s Private Education Loan Portfolio (including assurances regarding improving credit quality), the sufficiency of the Company’s loan loss provisions, and the Company’s 2015 core earnings guidance were proven false when the Company was forced to slash core earnings guidance by nearly 16% and significantly increase its provisions for loan losses on July 13, 2015. While Defendants may argue that their representations were accurate at the time they were made—and only became inaccurate as the result of changed circumstances—we believe such arguments are belied by the Company’s own admissions.50 Critically, the Company’s explanation that elevated default rates for loans that had entered repayment status in 2014 would require significantly increased provisions for loan losses demonstrates that the Company’s previously issued (and reaffirmed) guidance and assurances regarding improving credit quality falsely concealed that the overall credit quality of the Company’s Private Education Loan Portfolio was already declining. Indeed, the fact that credit quality had been declining—not improving—is further confirmed by the Company’s acknowledgement that the “segment of higher risk private education loan borrowers who returned to school during the recession deferred repayment on their existing loans and exited deferment status in 2014” were “experiencing unfavorable credit trends compared to loans that exited deferment in prior years” and represented an outsized portion of the Company’s portfolio (“$2.5 billion in 2014, as compared to $1.8 billion in 2013”). Such admissions directly contradict Defendants’ statements                                                              48 See, e.g., Q4 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, January 22, 2015 (“We are confident in our ability to generate core earnings per share of $2.20 in 2015, and to generate ongoing EPS growth in the years beyond.”); Q1 2015 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, April 22, 2015 (“I continue to remain confident in our ability to generate core earnings per share of $2.20 for the year and our ability to lead the industry in helping customers successfully manage their loans and to execute on our growth initiatives.”). 49 See, e.g., Navient Corporation, Form 10-Q filed May 9, 2014 (“Navient prides itself in a robust compliance culture driven by a ‘customer first’ approach.”); 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, July 17, 2014 (“Our loan servicing associates work closely with borrowers to find repayment solutions that not only keep borrowers out of default, but help them make real progress in repaying their debt balances.”); Q4 2014 Navient Corp Earnings Call – Final, FD (FAIR DISCLOSURE) WIRE, January 22, 2015 (“. . . Navient is leading the way with more customers enrolled in affordable repayment programs, and dramatically lower default rates, compared to the national average.”); Navient Corporation, Form 8-K filed April 21, 2015 (“We’re pleased to begin our first full year as Navient by helping more recent college graduates successfully transition into repayment.”). 50 Defendants’ potential challenge will likely rely upon the general principle that “[t]o be actionable, a statement or omission must have been misleading at the time it was made [and] liability cannot be imposed on the basis of subsequent events.” OFI Risk Arbitrages v. Cooper Tire & Rubber Co., 2015 U.S. Dist. LEXIS 85510 (D. Del. July 1, 2015) (Andrews, J.) (quoting In re NAHC, Inc. Sec. Litig., 306 F.3d 1314, 1330 (3d Cir. 2002)).   12 throughout 2014 and 2015 touting improving credit trends—most jarringly, Defendants’ April 22, 2015 assurance that “the class of 2014, which recently entered repayment, is showing the best performance of any recent graduating class.” Similarly, Defendants may argue that representations regarding the sufficiency of Navient’s loan loss provisions are “soft” statements of “opinion” that are actionable “[only] if the speaker does not genuinely and reasonably believe them.” In re Wilmington Trust Sec. Litig., 29 F. Supp. 3d 432, 452 (D. Del. 2014) (quoting In re Donald J. Trump Casino Sec. Litig., 7 F.3d 357, 368-69 (3d Cir. 1993)). While assurances regarding the adequacy of loan loss reserves likely qualify as opinion, we believe that these assurances “were both false and not honestly believed when they were made,” and thus, are actionable. Id. (quoting Fait v. Regions Fin. Corp., 655 F.3d 105 (2d Cir. 2011)). As explained in more detail below, we believe the Company was aware that student loans entering repayment status in 2014 were performing poorly versus prior loans, and were resulting in significantly increasing credit risk that warranted additional loan loss provisions. Accordingly, Defendants representations regarding the sufficiency of its loan loss provisions are likely actionable. Separately, Defendants may attempt to argue that the Company’s 2015 core earnings guidance is inactionable pursuant to the PSLRA’s “safe harbor” protecting forward-looking statements. See Institutional Investors Grp. v. Avaya, Inc., 564 F.3d 242, 253-54 (3d Cir. 2009). In order to successfully apply the safe harbor, Defendants must establish that the earnings guidance was “accompanied by meaningful cautionary statements” that were ‘extensive, specific, and directly related to the alleged misrepresentation.” In re Aetna Sec. Litig., 617 F.3d 272, 282 (3d Cir. 2010). While such a defense is possible here, we believe safe harbor arguments are not persuasive given that the safe harbor is not applicable to statements that are knowingly false when made. See In re SeeBeyond Techs. Corp. Sec. Litig., 266 F. Supp. 2d 1150, 1165 (C.D. Cal. 2003) (“If the forward-looking statement is made with actual knowledge that it is false or misleading, the accompanying cautionary language can only be meaningful if it either states the belief of the speaker that it is false or misleading or, at the very least, clearly articulates the reasons why it is false or misleading.”); Rombach v. Chang, 355 F.3d 164, 173 (2d Cir. 2004). Indeed, the Company’s generic warnings that it may not be able to meet its earnings guidance if student loan servicing trends deteriorate is inadequate given that the negative servicing trends had already materialized when the “higher risk” loans began to exit deferment status in 2014. See Rombach, 355 F.3d at 173 (“Cautionary words about future risk cannot insulate from liability the failure to disclose that the risk has transpired”). Improper Student Loan Servicing Practices   Separately, Defendants repeated assurances that the Company “prides itself in a robust compliance culture driven by a ‘customer first’ approach” and “work[s] closely with borrowers to find repayment solutions that not only keep borrowers out of default, but help them make real progress in repaying their debt balances” have been proven false by the February 27, 2015, August 24, 2015, September 29, 2015, December 28, 2015, and February 6, 2016 disclosures. Collectively these disclosures alerted investors to the fact that the Company’s use of improper and questionable servicing practices would have a significant impact on the Company’s operations—namely, the Company’s Pioneer subsidiary would lose its debt collection contract with the ED, Navient would face significant scrutiny and potential legal action from the CFPB,   13 the Company would lose access to a significant portion of its existing credit facilities with the FHLB-DM due to political pressure, and Secretary Clinton would publicly scold the Company for its “misleading” and “outrageous” conduct. Notwithstanding these disclosures, Defendants may argue that statements regarding the Company’s commitment to their borrowers and compliance are not material because they constitute inactionable “puffery.” As recognized by the Third Circuit, certain categories of statements are not considered material because they would not be relied upon by reasonable investors. See Aetna, 617 F.3d at 283. Specifically, statements of subjective analysis, opinion, optimism, motive, intent, and statements may be found to be “too vague” to be actionable. Id. Defendants are likely to assert that assurances regarding the propriety of the Company’s servicing practices were too vague to be actionable. See In re Wachovia Sec. Litig., 753 F. Supp. 2d 326 (S.D.N.Y. 2011) (finding that assertions of “conservative” underwriting standards were vague puffery). While, in the abstract, representations that the Company puts “customer[s] first” and employs servicing practices that benefit borrowers may lack sufficient meaning to be relied upon by investors, “[t]he puffery rule does have an outer boundary” where puffery “becomes an actionable, ‘factual’ misstatement … when ‘(1) the statement is not actually believed, (2) there is no reasonable basis for the belief, or (3) the speaker is aware of undisclosed facts tending seriously to undermine the statement’s accuracy.’” CornerStone Propane Partners, L.P. Sec. Litig., 355 F. Supp. 2d 1069, 1087 (N.D. Cal. 2005) (citations omitted); see also Shapiro v. UJB Fin. Corp., 964 F.2d 272, 282 (3d Cir. 1992) (“[I]f a defendant represents that its lending practices are “conservative” . . . the securities laws are clearly implicated if it nevertheless intentionally or recklessly omits certain facts contradicting these representations.”). Taken in the context of the ultimate disclosures that the Company’s conduct rose to the level of prompting the CFPB to propose regulatory changes and contemplate legal action, the ED’s decision to not renew Pioneer’s contract, and the FHLB-DM’s decision to drastically reduce Navient’s credit facilities, Defendants’ statements gave investors the materially false impression that the Company’s servicing practices actually went beyond the minimum requirements. See F.T.C. v. Trudeau, 579 F.3d 754, 766 (7th Cir. 2009) (“In determining whether a statement is puffery, the context matters.”). For these reasons, we do not believe Defendants would be successful in making a puffery defense. Separately, Defendants may also rely on the “truth on the market” defense to argue that, even if they failed to adequately disclose material information regarding the Company’s use of improper servicing practices, the market had already been sufficiently informed of such facts by third-party sources. Under the “truth on the market” defense, “a misrepresentation is immaterial if the information is already known to the market because the misrepresentation cannot then defraud the market.” Ganino v. Citizens Utilities Co., 228 F.3d 154, 167 (2d Cir. 2000); see also Allstate Ins. Co. v. Countrywide Financial Corp., 824 F. Supp. 2d 1164, at 1184 n.25 (C.D. Cal. 2011) (“The ‘truth on the market’ defense can fairly be characterized as a defense to materiality, reliance, or loss causation, or as a separate affirmative defense.”). To this end, Defendants will likely assert that concerns regarding Navient’s servicing practices were already in the public domain in the form of media reports covering borrower complaints, government concerns, and the prior disclosure of the CFPB investigation. However, “[w]hether . . . problems were adequately disclosed to the market is a fact- intensive query that cannot be disposed of on a motion to dismiss.” Hall v. The Children’s Place   14 Retail Stores, Inc., 580 F. Supp. 2d 212, 229 (S.D.N.Y. 2008). Given the fact intensive nature of the truth on the market defense, courts are hesitant to apply this doctrine at early stages of litigation. See In re Bank of Am. Corp. Sec., Derivative, & ERISA Litig., 757 F. Supp. 2d 260 (S.D.N.Y. 2010) (“A truth-on-the-market defense is intensely fact-specific and is rarely an appropriate basis for dismissing a § 10(b) complaint for failure to plead materiality.”); see also Allstate., 824 F. Supp. 2d at 1184-85 (“falsity and materiality (and particularly the truth-on-the- market defense to materiality) are mixed questions of law and fact that are more appropriately considered at summary judgment”). Moreover, courts have recognized that “[t]here are serious limitations on a corporation’s ability to charge its stockholders with knowledge of information omitted from a document . . . on the basis that the information is public knowledge and otherwise available to them.” Kronfeld v. Trans World Airlines, Inc., 832 F.2d 726, 736 (2d Cir. 1987). Indeed, the Company’s statements in its SEC filings served to directly rebut any belief that the Company’s practices were improper. Accordingly, it is unlikely that the truth on the market defense would provide Defendants with a strong basis to dismiss investors’ claims. B. Scienter  In order to satisfy the scienter element, a plaintiff must “state with particularity facts giving rise to a strong inference that the defendant acted with the required state of mind.” 15 U.S.C. § 78u-4(b)(2); see also Tellabs v. Makor Issues & Rights, Ltd., 551 U.S. 308, 319 (2007) (noting that scienter is defined as “a mental state embracing intent to deceive, manipulate or defraud”). Scienter is defined in the Third Circuit as “a mental state embracing intent to deceive, manipulate, or defraud, and requires a knowing or reckless state of mind.” City of Roseville Emps.’ Ret. Sys. v. Horizon Lines, Inc., 442 F. App’x 672, 674 (3d Cir. 2011); see also Tellabs v. Makor Issues & Rights, Ltd., 551 U.S. 308, 319 (2007) (defining scienter as “a mental state embracing intent to deceive, manipulate or defraud”). A “reckless statement” involves “not merely simple, or even inexcusable negligence, but an extreme departure from the standards of ordinary care, and which presents a danger of misleading buyers or sellers that is either known to the defendant or is so obvious that the actor must have been aware of it.” Institutional Investors Group v. Avaya, Inc., 564 F.3d 242, 267 (3d Cir. 2009); see also In re Advanta Corp. Sec. Litig., 180 F.3d 525, 535 (3d Cir. 1999). One way to establish scienter is to demonstrate that the speaker making the statement was aware of information that contradicted the statement at the time the statement was made. See Winer Family Trust v. Queen, 503 F.3d 319, 332-33 (3d Cir. 2007). Assuming that the alleged misstatements are found to be false and misleading, we believe the presently known facts may collectively support allegations of scienter. See Tellabs, 551 U.S. at 322 (the inquiry “is whether all of the facts alleged, taken collectively, give rise to a strong inference of scienter, not whether any individual allegation, scrutinized in isolation, meets that standard”). “In most cases, the most straightforward way to raise [an inference of scienter] for a corporate defendant will be to plead it for an individual defendant.” Teamsters Local 445 Freight Division Pension Fund v. Dynex Capital, Inc., 531 F.3d 190, 195 (2d Cir. 2008). As such, if plaintiffs can establish scienter as to the Officer Defendants, scienter would be imputed to Navient. Here, our analysis suggests that the Officer Defendants acted with scienter by misleading investors regarding the strength of Navient’s business prospects and student loan portfolios, the   15 sufficiency of Navient’s loan loss reserves, and the propriety of Navient’s student loan servicing practices. As Navient’s Chief Executive Officer and Chief Financial Officer, the Officer Defendants would have been critically involved in overseeing the Company’s business model and would have had personal knowledge that the Company was experiencing negative credit trends pertaining to loans entering repayment in 2014 and was exposed to significant regulatory and political risks due to the use of improper servicing practices. See Wachovia Equity Sec. Litig., 753 F. Supp. 2d 326, 353 (S.D.N.Y. 2011) (“the Court considers ‘core operations’ allegations to constitute supplementary but not independently sufficient means to plead scienter”); South Ferry LP v. Killinger, 542 F.3d 776, 785-86 (9th Cir. 2008) (“allegations regarding management’s role in a company may be relevant and help to satisfy the PSLRA scienter requirement”). Moreover, the fact that Defendants repeatedly discussed the purportedly improving credit climate—and made it a focus of each quarterly discussion of Navient’s financial results—further demonstrates that the Officer Defendants were aware or should have been aware of the fact that significant credit risks were undermining the Company’s earnings and rendered existing loan loss provisions insufficient to cover expected student loan defaults. See In re Longtop Fin. Techs. Ltd. Sec. Litig., 910 F. Supp. 2d 561, 578 (S.D.N.Y. 2012) (“failing to detect a fraud of large magnitude provides some circumstantial evidence of scienter, just as failing to detect a large boulder in front of your face qualifies as circumstantial evidence of blindness”). Furthermore, Defendants’ desire to maximize capital generated through the three Senior Notes offerings—collectively raising nearly $1.5 billion in proceeds for Navient—further supports an inference of scienter. See In re Twinlab Corp. Sec. Litig., 103 F. Supp. 2d 193, 206 (E.D.N.Y. 2000) (“to inflate the stock price to maximize revenue from the secondary offering, so as to provide it capital” is a sufficient allegation of motive); In re MicroStrategy Inc. Sec. Litig., 115 F. Supp. 2d 620, 648 (E.D. Va. 2000) (finding defendants’ desire to raise capital through public offerings, combined with other allegations, probative of scienter). Nevertheless, we note that Defendants will be permitted to provide non-culpable explanations to rebut plaintiffs’ scienter allegations. See Winer Family Trust v. Queen, 503 F.3d 319, 328-33 (3d Cir. 2007) (relying on non-culpable explanations to dismiss claims). Here, Defendants’ arguments will likely track their defenses to falsity. As noted above, Defendants will likely argue that at the time they were touting the improving credit climate and the sufficiency of Navient’s loan loss provisions, and were putting forth core earnings guidance of $2.20 per share, issues surrounding loans entering repayment in 2014 had not yet manifest—or if issues had started to materialize the Officer Defendants were not aware of such issues. Moreover, Defendants may also attempt to argue that even if certain Navient employees were engaged in improper servicing practices, the Officer Defendants were not aware of such conduct. While such explanations are plausible, we believe there is more likely that such defenses will fail. Here, Defendants’ own admissions regarding the poor performance of loans entering repayment in 2014 suggest that it is highly unlikely that the Officer Defendants were unaware of these issues both throughout 2014 and as recently as April 2015 when the Company reaffirmed its core earnings guidance for 2015. Indeed, the timing and magnitude of the loan loss provision strongly suggests that, to the extent the Officer Defendants were unaware of the negative trends impacting loans entering repayment in 2014, such obliviousness would have been reckless and sufficient to raise an inference of scienter. See Novak v. Kasaks, 216 F.3d 300, 308 (2d Cir.   16 2000) (“we have found allegations of recklessness to be sufficient where plaintiffs alleged facts demonstrating that defendants failed to review or check information that they had a duty to monitor, or ignored obvious signs of fraud”). Similarly, given the intense scrutiny on loan servicers, including an ongoing investigation into Navient prior to the spin-off strongly suggests that the Officer Defendants would have been aware of the Company’s use of certain improper and questionable servicing practices. Accordingly, it is unlikely that Defendants will be able to successfully defeat plaintiffs’ complaint based on a failure to plead scienter. Ultimately, we believe the presently known facts may provide a basis for pleading scienter. Moreover, if selected as lead counsel, Kessler Topaz will attempt to supplement these facts through additional investigation. C. Loss Causation  To plead loss causation in the Third Circuit, a plaintiff must allege that the price of a security was inflated due to a fraudulent misrepresentation, and “the drop in the value of [that] security is related to the alleged misrepresentation.” Berckeley Inv. Grp., Ltd. v. Colkitt, 455 F.3d 195, 222 (3d Cir. 2006); see also McCabe v. Ernst & Young, LLP, 494 F.3d 418, 425 (3d Cir. 2007) (differentiating between transaction causation and loss causation). No single disclosure revealing all aspects of a fraud is needed to plead loss causation. See, e.g., Freeland v. Iridium World Commc’ns, Ltd., 233 F.R.D. 40, 47 (D.D.C. 2006). Moreover, unlike other elements of Section 10(b) that must be pled with particularity, the loss causation element is met so long as a plausible connection is pled between the disclosure, the defendants’ misconduct, and a decline in the price of security. See Dura, 544 U.S. at 346. Here, as detailed above, the price of the Company’s common stock declined on the following dates in response to news correcting Defendants’ Class Period misstatements and omissions:  $1.89 per share, or approximately 9%, from a close of $21.40 per share on February 27, 2015 to close at $19.51 per share on March 2, 2015;  $1.94 per share, or approximately 11%, from a close of $18.36 per share on July 13, 2015, to close at $16.42 per share on July 14, 2015;  $1.85 per share, or approximately 13%, from a close of $13.89 per share on August 23, 2015, to close at $12.04 per share on August 25, 2015;  $1.20 per share, or approximately 10%, from a close of $12.16 per share on September 28, 2015, to close at $10.96 per share on October 1, 2015;  $1.15 per share, or approximately 9%, from a close of $12.61 per share on December 24, 2015, to close at $11.46 per share on December 28, 2015; and  $0.57 per share, or more than 6% from a close of $9.51 per share on February 5, 2016, to close at $8.94 per share on February 8, 2016.   17       Given these declines, and the lower standard for pleading loss causation, we do not expect pleading loss causation will be an issue at the motion to dismiss stage of litigation.51 II. Section 20(a)  We believe plaintiffs can plead Section 20(a) claims against the Officer Defendants as control persons of the Company. Plaintiffs seeking to prove a Section 20(a) claim must allege: “(1) one person controlled another person or entity; (2) that the controlled person or entity committed a primary violation of the securities laws; and (3) that the defendant was a culpable participant in the fraud.” Belmont v. MB Inv. Partners, Inc., 2010 U.S. Dist. LEXIS 57822 (E.D. Pa. June 10, 2010). Here, the Officer Defendants would be liable under Section 20(a) if claims against Navient under Section 10(b) are sustained. III. Securities Act Claims  Investors who purchased Navient debt securities pursuant to the Offerings may also be able to recover under Sections 11, 12(a)(2), and 15 of the Securities Act.52 While purchase in                                                              51 While Defendants may argue that the full extent of the declines is not attributable to revelations of fraud, courts have frequently held that such arguments are improper at the early stages of litigation. See Hill v. State St. Corp., 2011 U.S. Dist. LEXIS 85128, at *64 (D. Mass. Aug. 3, 2011) (“At [the motion to dismiss] stage in the litigation, it is premature to unravel all of the factors that triggered the market’s reaction.”); In re Daou Sys., 411 F.3d 1006, 1025 (9th Cir. 2005) (“A plaintiff is not required to show ‘that a misrepresentation was the sole reason for the investment’s decline in value’ in order to establish loss causation.”). 52 Based on our review of ABC Employees Retirement System’s trading, it does not appear that ABC Employees’ Retirement System acquired any Navient debt securities pursuant to the Offerings. Nevertheless, ABC Employees’ Retirement System would be permitted to serve as lead plaintiff on behalf of investors asserting Securities Act claims. 2/27/15: ED cancels contract with Navient subsidiary (-9%) 7/13/15: Navient slashes 2015 earnings guidance; increases loan loss provisions (-11%) 8/24/15: CFPB threatens legal action (-13%) 9/29/15: CFPB publishes report on student loan servicers (-10%) 12/28/15: FHLB-DM reduces Navient’s credit facilities (-9%) 2/6/16: Hillary Clinton attacks Navient’s practices (-6%)   18 the Offerings allows pleading both Securities Act and Exchange Act claims in connection with those purchases, double recovery is prohibited. Section 11 imposes liability for issuing false and misleading statements and omitting material information from a registration statement. To state a claim under Section 11, plaintiffs must allege that “the registration statement … contained an untrue statement of a material fact or omitted to state a material fact required to be stated therein or necessary to make the statements therein not misleading.” 15 U.S.C. § 77k(a). A claim under Section 11 may be asserted against every person who signed the registration statement and the directors of the issuer at the time of the offering. 15 U.S.C. § 77k(a)(l)-(2). Similarly, Section 12(a)(2) creates liability for a seller of a security based on statements contained in a prospectus. Accordingly, Section 11 and 12(a)(2) claims could be asserted against Navient, the Officer Defendants, certain Navient directors, and the underwriters of the Navient debt securities sold in the Offerings. Establishing liability under Section 11 and 12(a)(2) is generally easier than establishing liability under Section 10(b) of the Exchange Act. While the issuer of securities is strictly liable under Section 11 (here, Navient), Sections 11 and 12(a)(2) provide an affirmative defense of “due diligence” to defendants other than the issuer of the security—the defendants, however, carry the burden of establishing this defense. See Herman & MacLean v. Huddleston, 459 U.S. 375, 382 (1983) (“Liability against the issuer of a security is virtually absolute, even for innocent misstatements. Other defendants bear the burden of demonstrating due diligence.”); Ernst & Ernst v. Hochfelder, 425 U.S. 185, 208 (1976). Moreover, unlike claims under Section 10(b), plaintiffs asserting liability under Section 11 and 12(a)(2) are not required to plead scienter, reliance, or loss causation, nor must the allegations satisfy the heightened pleading standard of Rule 9(b) of the Federal Rules of Civil Procedure. See Rafton v. Rydex Series Funds, 2011 U.S. Dist. LEXIS 707, at *17-18 (N.D. Cal. Jan. 5, 2011). Nevertheless, establishing falsity and materiality will largely track the arguments discussed above regarding liability under Section 10(b) of the Exchange Act. Furthermore, Section 15 of the Securities Act, like Section 20(a) of the Exchange Act, creates control person liability. Plaintiffs seeking to prove a Section 15 claim must establish: (1) a primary violation of the Sections 11 or 12(a)(2); and (2) that the defendant exercised actual power or control over the primary violator. Here, the Officer Defendants and certain Navient directors would be liable under Section 15 if claims against Navient under Section 11 are sustained. IV. ABC Employees’ Retirement System ‐Specific Considerations  A. Potential Standing Challenges  As ABC Employees’ Retirement System is aware, asset managers that invest in securities through multiple funds and sub-funds—like ABC Employees’ Retirement System —have been challenged by competing movants at the lead plaintiff stage of litigation for lacking standing to assert claims in connection with securities held by their respective funds and sub-funds. While a competing movant may lob such challenges against ABC Employees’ Retirement System in this litigation, we believe such arguments will not be successful. As an initial matter, ABC Employees’ Retirement System has been previously found to have standing to assert claims in   19 connection with investments by its funds.53 More importantly, in OFI Risk Arbitrages v. Cooper Tire & Rubber Co., the Honorable Richard G. Andrews of the District of Delaware dismissed such standing attacks as “rely[ing] on mere speculation” and, in a thorough opinion, appointed a European asset manager as lead plaintiff. 63 F. Supp. 3d 394, 403-05 (D. Del. 2014). As such, we believe the court in the Navient litigation will reject any attacks on ABC Employees’ Retirement System’s standing. B.  ABC Employees’ Retirement System’s Trading History and Recoverable Losses  Based on our analysis of ABC Employees’ Retirement System’s trading history in Navient common stock, ABC Employees’ Retirement System sold an overwhelming majority of its Navient holdings prior to the August 24, 2015 corrective disclosure (concerning the CFPB’s threatened legal action) but after the February 27, 2015 corrective disclosure (the ED’s announcement to not renew the Pioneer contract) and the July 13, 2015 corrective disclosure (revealing that Navient’s credit condition was worse than represented, Navient’s loan loss provisions were insufficient, and Navient’s earnings guidance would be reduced by approximately 16%). Accordingly, ABC Employees’ Retirement System’s ability to recover losses will be largely tied to its ability to establish the sufficiency of the February 2015 and July 2015 corrective disclosures. Nevertheless, ABC Employees’ Retirement System appears to have retained a portion of its investment through the end of the Class Period, and thus, has an interest in establishing the sufficiency of the August 2015, September 2015, December 2015, and February 2016 corrective disclosures. See Foley v. Transocean Ltd., 272 F.R.D. 126, 132 (S.D.N.Y. 2011) (appointing lead plaintiff whose “shares were sold after partial corrective disclosures” and noting that “loss causation ‘does not require full disclosure, and can be established by partial disclosure during the class period which causes the price of shares to decline’”); Juliar v. SunOpta, Inc., 2009 WL 1955237, at *2 (S.D.N.Y. Jan. 30, 2009) (“where a putative lead plaintiff sold all its shares after a partial disclosure of misconduct by the defendant but before the final disclosure that led to the lawsuit, that putative lead plaintiff does not face the unique defense of having to show loss causation to the extent that it cannot serve as lead plaintiff.”). CONCLUSION  Although our analysis is ongoing, we believe the publicly available facts are likely sufficient to plead actionable claims under Sections 10(b) and 20(a) of the Exchange Act and Sections 11, 12(a)(2), and 15 of the Securities Act. Accordingly, we recommend that ABC Employees’ Retirement System consider seeking appointment as lead plaintiff by the April 11, 2016 deadline.                                                              53 See City of Taylor Police & Fire Ret. Sys. v. Western Union Co., 2014 U.S. Dist. LEXIS 136101 (D. Colo. Sept. 26, 2014) (concluding that “concerns about ABC Employees’ Retirement System’s standing are unfounded”). EXHIBIT C TO ABC Employees’ Retirement System FROM Darren J. Check, Esquire DATE April 26, 2016 RE Brixmor Property Group Inc. Class Action MEMORANDUM: PRIVILEGED ATTORNEY/CLIENT COMMUNICATION DATE CASE FILED March 31, 2016 LEAD PLAINTIFF DEADLINE May 31, 2016 CLASS PERIOD October 27, 2014 – February 5, 2016 JURISDICTION United States District Court, Southern District of New York JUDGE The Honorable Analisa Torres THE CASE AGAINST BRIXMOR PROPERTY GROUP INC.1: The Complaint charges the Company and certain of its former officers (the “Individual Defendants”) with violations of the Securities Exchange Act of 1934 (the “Exchange Act”).2 Brixmor, a Maryland corporation headquartered in New York, New York, is a real estate finance company that owns and rents commercial real estate for grocery stores and is organized as a real estate investment trust. The Complaint alleges that throughout the Class Period, Defendants made false and misleading statements and failed to disclose material adverse facts about the Company’s business and operations. Specifically, Defendants falsely assured investors that: (1) same property net operating income (“NOI”) had shown consistent growth in prior financial reporting periods; and (2) the Company maintained adequate internal controls over financial reporting. As set forth in the Complaint, on February 8, 2016, Brixmor disclosed that the Company’s “accounting and financial reporting personnel” were directly involved in “smoothing income items between reporting periods in a manner contrary to GAAP in an effort to achieve consistent quarterly same property net operating income growth.” Brixmor also announced the immediate resignations of Defendants Carroll, Pappagallo, and Splain. On this news, the price of Company shares declined $5.32 per share, or more than 20%, from a close of $26.42 per share on February 5, 2016, to close at $21.10 per share on February 8, 2016. The following summarizes the securities class action litigation filed against Brixmor Property Group Inc. (“Brixmor” or the “Company”) (NYSE: BRX): LOSSES SUFFERED by ABC Employees’ Retirement System TOTAL LOSS $156,240.00 1 The basis for this analysis comes from, inter alia, the allegations pled in Westchester Putnam Counties Heavy and Highway Laborers Local 60 Benefit Funds v. Brixmor Property Group, Inc. et al., No. 16-cv-02400 (S.D.N.Y. filed March 31, 2016). 2 The Individual Defendants named in the Complaint include: Michael A. Carroll (the Company’s Chief Executive Officer until February 7, 2016); Michael V. Pappagallo (the Company’s President and Chief Financial Officer until February 5, 2016); and Steven A. Splain (the Company’s Chief Accounting Officer until February 7, 2016). As an initial matter, falsity is established by the Company’s admission that its accounting and financial reporting personnel intentionally misstated NOI in previously issued financial results. Additionally, materiality may be supported as accurate financial reporting, and effective internal controls over financial reporting, are likely to be considered by investors when determining whether to purchase Company shares and assessing the risk of doing so. Loss causation may also be supported by the decline in the price of Company shares following the February 8, 2016 disclosure. Lastly, the resignations of the Individual Defendants may support an inference of scienter. As a primary challenge to liability, the Individual Defendants are likely to claim that the Company’s previously reported NOI misstatements were not material to the Company’s financial statements. Separately, certain investors may not have recoverable losses as the Company’s stock price has recovered a substantial portion of the February 8, 2016 decline. INITIAL ESTIMATE OF CLASS DAMAGES: $330M KESSLER TOPAZ RECOMMENDATION: Remain a Passive Class Member STRENGTHS WEAKNESSES EXHIBIT D ABC Employees’ Retirement System QUARTERLY SECURITIESQUARTERLY SECURITIES LITIGATION UPDATE QUARTER ENDING MARCH 31, 2016 INTRODUCTION  The following is an update of the portfolio monitoring services provided by Kessler Topaz Meltzer & Check, LLP (“Kessler Topaz”) for ABC Employees’ Retirement System. The report includes an overview of U.S. and Non-U.S. financial market performance during the past quarter and securities class action information for securities relevant to ABC Employees’ Retirement System’s portfolio. Depending on the securities relevant to ABC Employees’ Retirement System portfolio, the report may contain sections for monetary and non-monetary settled litigation, and new and ongoing litigation for both U.S. and Non- U.S. litigation. Information regarding ABC Employees’ Retirement System’s financial interest during the Class Period provided for new litigation may vary from information previously reported by Kessler Topaz if the Class Period has changed or additional transaction records have since become available. If you have any questions regarding this report please contact Darren J. Check, Esq. at 610.822.2235 or dcheck@ktmc.com. Q1  2016  2 U.S. MARKET OVERVIEW  The first quarter of 2016 proved to be volatile but two of the three major U.S. indices ending the quarter about where they began. This was relatively good news, as the first quarter began in a very negative manner and moved down, to a low in mid-February. Market sentiment was affected throughout most of the quarter by continued falling oil prices and the effect the low prices have had on all oil companies, particularly on smaller companies in the oil and gas sector with levered balance sheets—even extending to the banks in the U.S. that have provided this leverage. However, in March, investors began to gauge excess supply in the oil market was eroding and bid up the commodity, which had a positive effect on the markets at large. The NASDAQ was the worst performer over the quarter; this included a slowed market for initial public offerings significantly—down 73% year-over-year. The Federal Reserve’s commentary, which is a market-driver, was viewed by many as inconsistent throughout the quarter: initially three to four interest rate increases in 2016 were expected, but the Fed turned more “dovish” from mid-March through the end of the quarter. The Fed did not choose to raise interest rates at its March meeting, as was expected, but signaled that there may only be two rate increases in all of 2016. COMPARISON OF US STOCK INDICES  PRICE CHANGE   Close at 12/31/2015 Close at 3/31/2016 % Change  DOW Jones 17,425.0 17,685.1 1.5 %  S & P 500 2,043.9 2,059.7 0.8 %  NASDAQ 5,007.4 4,869.9 ‐2.7 %  Q1  2016  3 NON‐U.S. MARKET OVERVIEW  The European markets experienced a slowdown in the first quarter and continued the quarterly drop from the fourth quarter of 2015. Investors, including many mutual funds, have been selling out of European companies due to concerns about economic growth in the region. Central Bankers in Europe and Asia have continued to try to avoid deflationary scenarios in their economies. The Bank of Japan dropped interest rates into the negative territory in January, surprising both European and U.S. markets, with a rate of -0.1% to current accounts held at the bank. The European Central Bank (ECB) further cut rates on March 10, charging banks 0.4% to hold their cash overnight. At the same time, it offered a premium to banks that borrow in order to extend more loans and drive growth in the region. The DAX in Germany took the largest hit due to the proportion of financial firms and automakers (notably Volkswagen AG) that comprise the index. Meanwhile, the FTSE 100 was nominally down over the quarter, but has contended with the concern of the possibility of ‘Brexit’ for the three month period. COMPARISON OF NON‐U.S. STOCK INDICES    PRICE CHANGE  Close at 12/31/2015 Close at 3/31/2016 % Change  DAX 10,743.0 9,965.5 ‐7.2 %  FTSE 100 6,242.3 6,174.9 ‐1.1 %  Stoxx Europe 600 365.8 337.5 ‐7.7 %  Q1  2016  4 SETTLED LITIGATION (Eligible to file claims)  Based on a preliminary analysis of the transactions provided to Kessler Topaz, ABC Employees’ Retirement System is eligible to file proof(s) of claim in the following securities class action settlement(s) that have been announced this Quarter. Kessler Topaz is responsible for submitting proof(s) of claim on behalf of ABC Employees’ Retirement System and has filed or is in the process of preparing proof(s) of claim to file in the below settlement(s). Please be advised that meeting the eligibility requirements to file a claim does not guarantee that the claim will be eligible to receive a recovery under the Court-approved plan of allocation. CLASS PERIOD TRANSACTIONS IDENTIFIED FOR   SETTLEMENT CLAIMS DEADLINE CLASS PERIOD SETTLEMENT AMOUNT BIOSCRIP, INC. (2013) 6/12/2016 11/09/12 ‐ 11/06/13 $10,900,000  GENERAL MOTORS COMPANY   (2014) 4/27/2016 11/17/10 ‐ 07/24/14 $300,000,000  HCA HOLDINGS, INC. (2011) 4/26/2016 03/09/11 ‐ 10/28/11 $215,000,000  IXIA (2013) 6/23/2016 02/04/11 ‐ 04/03/13 $3,500,000  JPMORGAN CHASE & CO. (2012) 6/13/2016 04/13/12 ‐ 05/21/12 $150,000,000  MERCK & CO., INC. (2003) 9/12/2016 05/21/99 ‐ 10/29/04 $830,000,000  SPECTRUM PHARMACEUTICALS,  INC. (2013) 6/9/2013 08/08/12 ‐ 03/12/13 $7,000,000      Q1  2016  5 NON‐MONETARY SETTLEMENTS  During the past quarter, non-monetary settlements were reached in the following cases in which ABC Employees’ Retirement System currently has a financial interest:   COMPANY: AmREIT, Inc.    CLASS PERIOD: 07/10/14 ‐ 02/20/15    SETTLEMENT DESCRIPTION:  CASE SUMMARY  The Complaint alleges that AmREIT's Board of Directors (the "Board") breached their fiduciary duties to AmREIT shareholders by engaging in an unfair process and self-interested conduct that led to the decision to sell AmREIT to Edens at an inferior price that did not reflect the market value for AmREIT. This conduct included failing to adequately consider a proposal by Regency Centers Corporation ("Regency"), a competitor of AmREIT, to purchase AmREIT for $22 in cash and/or stock. Instead, Plaintiffs alleged that the Board took actions to stop the Regency offer and took further actions to conduct a sales process for the Company that would enable the Board to select a preferred buyer for AmREIT that would provide its management and directors with financial benefits. For instance, Plaintiffs allege that the Board required all parties that were interested in buying AmREIT to enter into standstill agreements that prevented an interested party from buying AmREIT, outside of the sales process dictated by the Company. According to the Complaint, the standstill agreements did not allow for a potential buyer of the Company to make a higher bid for AmREIT than what was ultimately paid by Eden. In addition, the proxy materials filed with the Securities and Exchange Commission which explained the sale of AmREIT to Eden misrepresented and concealed material information that prevented AmREIT shareholders from making an informed decision whether to vote their shares in favor of the sale of AmREIT to Edens. SETTLEMENT PROVISIONS  In consideration for the Settlement of this Action, AmREIT: (i) agreed to the waiver of standstill agreements that it had entered into with any interested party since July 10, 2014 in connection with the review of strategic alternatives conducted by AmREIT's Board and was publicly announced on July 16, 2014, solely to the extent necessary to permit any such interested party to bring a fully funded tender offer for all of the shares of AmREIT; and (ii) made additional disclosures in a Schedule 14A dated January 12, 2015 and filed with the Securities and Exchange Commission. Q1  2016  6   COMPANY: Exelis, Inc.    CLASS PERIOD: 09/17/14 ‐ 05/29/15    SETTLEMENT DESCRIPTION  CASE SUMMARY  The Claim arises out for Breach of fiduciary duties in connection with Harris Corporation's ("Harris") proposed acquisition of all the outstanding stock of Exelis. On February 5, 2015, Exelis and Harris announced that they had entered into a definitive Agreement and Plan of Merger (the "Merger Agreement") under which Harris will acquire all outstanding shares of Exelis (the "Proposed Transaction"). Pursuant to the Merger Agreement, Exelis shareholders will receive consideration equal to $16.625 in cash and 0.1025 Harris common shares (the "Merger Consideration") for each share of the Company's common stock they own. The Merger Consideration represents a value of $23.75 per share for Exelis common stock. The Proposed Transaction has an enterprise value of $4.75 billion and is expected to close in June, 2015. Upon closing, Harris shareholders will own approximately 85 percent of the combined company, and Exelis shareholders will own approximately 15 percent. The complaint alleges that both the Merger Consideration that Exelis shareholders stand to receive and the process by which Defendants propose to consummate the Proposed Transaction are fundamentally unfair to Plaintiff and all other public shareholders of the Company. SETTLEMENT PROVISIONS  In consideration for the Settlement and the release of all Released Claims, Exelis made the Supplemental Disclosures in the Form 8K filed with the SEC on or about May 11, 2015.   Q1  2016  7 NEW U.S. LITIGATION  NOBILIS HEALTH CORP. (2016)  Ticker NHC  Date Case Filed: 03/30/2015  Lead Plaintiff Deadline 05/29/2015  Class Period 10/16/14 – 03/25/15  Losses Suffered by ABC  Employees’ Retirement System  $443,924.81  The Complaint charges the Company and certain of its officers (the “Individual Defendants”) with violations of the Securities Exchange Act of 1934 (the “Exchange Act”)1. Nobilis, a Canadian corporation headquartered in Houston, Texas, owns and manages healthcare facilities including ambulatory surgical centers and other medical service centers. The Complaint alleges that throughout the Class Period, Defendants made false and misleading statements and failed to disclose material adverse facts about the Company’s business and operations. Specifically, Defendants issued false and misleading financial results for the Company’s 2014 fiscal year and the first and second quarters of fiscal year 2015, and falsely assured investors that the Company maintained adequate internal controls over financial reporting. As set forth in the Complaint, on October 9, 2015, Seeking Alpha published an article asserting, inter alia, that the Company’s acquisition strategy, complex structure, and accounting methods raised questions about its continued viability. The article also claimed that the Company was manipulating its reporting of certain subsidiaries’ revenues in order to inflate its overall revenues and revenue growth. On this news, the price of Company shares declined $1.42 per share, or more than 27%, from a close of $5.24 per share on October 8, 2015, to close at $3.82 per share on October 9, 2015. Then, on November 11, 2015, the Company announced that it would not timely file its quarterly report for the third quarter of fiscal 2015 due to the discovery of discrepancies in the Company’s accounting of certain non-cash assets. On this news, the price of Company shares declined $0.65 per share, or more than 18%, from a close of $3.60 per share on November 11, 2015, to close at $2.95 per share on November 12, 2015. On January 5, 2016, after the close of markets, the Company announced that it needed to restate its financial results for fiscal 2014 and for the first and second quarters of fiscal 2015, and that investors should no longer rely upon its previous reports for those periods. The Company explained that several accounting errors had been discovered regarding, inter alia, the accounting of warrants and options issued in certain private placements, the accounting of certain business combinations, and the reclassification of certain non-controlling interests in Company subsidiaries. Lastly, on January 7, 2016, the Company announced the resignation of Defendant Lloyd from his role as the Company’s Chief Executive Officer. On this news, the price of Company shares declined $0.63 per share, or more than 20%, from a close of $3.10 per share on January 6, 2016, to close at $2.47 per share on January 7, 2016. 1 The Individual Defendants named in the Complaint include: Christopher H. Lloyd (the Company’s Chief Executive Officer until January 6, 2016) and Kenneth J. Klein (the Company’s Chief Financial Officer since July 2015 and its Chief Accounting Officer since April 2015). Q1  2016  8 IMPRIVATA, INC. (2016)  Ticker IMPR  Date Case Filed 02/02/2016  Lead Plaintiff Deadline 04/02/2016  Class Period 07/30/15 – 11/02/15  Losses Suffered by ABC  Employees’ Retirement System  $29,824  The Complaint charges the Company, certain of its officers (the “Individual Defendants”)1, and certain of its controlling shareholders2[2] with violations of the Securities Exchange Act of 1934 (the “Exchange Act”). Imprivata, a Delaware corporation headquartered in Lexington, Massachusetts, provides information technology security solutions primarily to the healthcare industry, including authentication products and access-management technology. The Complaint alleges that throughout the Class Period, Defendants made false and misleading statements and failed to disclose material adverse facts about the Company’s business and operations. Specifically, Defendants issued false and misleading financial guidance. As set forth in the Complaint, on October 14, 2015, the Company announced disappointing preliminary financial results for the third quarter of fiscal 2015 which fell short of the Company’s previous revenue and earnings guidance. The Company explained that delays on certain customer deals, declines in product sales to non-healthcare clients, and weaker than expected sales to smaller hospitals were the primary causes of the weak results. On this news, the price of Company shares declined $5.31 per share, or nearly 31%, from a close of $17.31 per share on October 14, 2015, to close at $12.00 per share on October 15, 2015. Then, on November 2, 2015, the Company confirmed the preliminary third quarter fiscal 2015 financial results issued on October 14, 2015, and also downgraded its guidance for the remainder of the fiscal year. During an accompanying conference call with analysts and investors, Defendant Kalowski revealed that the Company’s revenue downturn may extend into fiscal year 2016. On this news, the price of Company shares declined $0.97 per share, or more than 9%, from a close of $10.39 per share on November 2, 2015, to close at $9.42 per share on November 3, 2015. 1 The Individual Defendants named in the Complaint include: Omar Hussain (the Company’s President and Chief Executive Officer); and Jeffrey Kalowski (the Company’s Chief Financial Officer). 2 The controlling shareholders named in the Complaint include: General Catalyst Group II, L.P.; Highland Capital Partners VI Limited Partnership; and Polaris Venture Partners III, L.P. Q1  2016  9 COMSCORE. (2016)  Ticker SCOR  Date Case Filed 03/10/2016  Lead Plaintiff Deadline 05/09/2016  Class Period 05/05/15 – 03/07/16  Losses Suffered by ABC  Employees’ Retirement System  $2,320,827  The Complaint charges the Company and certain of its officers (the “Individual Defendants”) with violations of the Securities Exchange Act of 1934 (the “Exchange Act”)1. The Company, a Delaware corporation headquartered in Reston, Virginia, provides digital media marketing services to businesses, including analytics that measure consumer interactions with digital media. The Complaint alleges that, throughout the Class Period, Defendants made false and misleading statements and failed to disclose material adverse facts about the Company’s business and operations. Specifically, Defendants made false and misleading statements and failed to disclose that comScore lacked adequate internal controls over its financial reporting, and, as a result, the Company would not be able to timely file its 2015 fiscal year-end annual report (“2015 Annual Report”). As set forth in the Complaint, on February 29, 2016, comScore informed the Securities and Exchange Commission (“SEC”) that it would not be able to file the 2015 Annual Report by the prescribed due date of February 29, 2016 because external audits of the 2015 Annual Report financial statements were still ongoing. The Company explained that “potential accounting matters” required further review of the financial statements but that it expected to file the required 2015 Annual Report by March 15, 2016, within the permitted 15-day extension from February 29, 2016. On this news, the price of Company shares declined $1.15 per share, or nearly 3%, from a close of $41.15 per share on February 29, 2016 to close at $40.00 per share on March 1, 2016. Then, on March 7, 2016, comScore disclosed that it did not anticipate filing the 2015 Annual Report before the March 15, 2016 extended deadline due to comScore’s continuing internal review and the additional assessment of that review required by the Company’s independent public accountants prior to filing financial reports with the SEC2. Additionally, comScore revealed that it would suspend a previously announced share repurchase program because of the uncertainty surrounding the Company’s filing of the 2015 Annual Report. On this news, the price of Company shares declined $13.67 per share, or 33.5%, from a close of $40.71 per share on March 4, 2016 to close at $27.04 per share on March 7, 2016. 1 The Individual Defendants named in the Complaint include: Serge Matta (the Company’s Chief Executive Officer and President); and Melvin Wesley III (the Company’s Chief Financial Officer). 2 After the Class Period, on March 18, 2016, comScore disclosed that NASDAQ had notified comScore that the Company was not in compliance with NASDAQ Listing Rule 5250(c)(1), which requires timely filing of financial reports with the SEC. Q1  2016  10 PRECISION CASTPARTS CORP. (2016)  Ticker PCP  Date Case Filed 03/25/2016  Lead Plaintiff Deadline 05/27/2016  Class Period 05/09/13 – 01/15/15  Losses Suffered by ABC Employees’  Retirement System  $630,376  The Complaint charges the Company and certain of its officers (the “Individual Defendants”) with violations of the Securities Exchange Act of 1934 (the “Exchange Act”)1. Precision, an Oregon corporation headquartered in Portland, Oregon, manufactures and sells complex metal components such as structural investment castings, forged products, and specialty fasteners for use in the aerospace industry. The Complaint alleges that throughout the Class Period, Defendants made false and misleading statements and failed to disclose material adverse facts about the Company’s business and operations. Specifically, Defendants made false and misleading statements concerning the market conditions for the Company’s products and failed to disclose the impact of weakening market demand on the Company’s financial projections. As set forth in the Complaint, on July 24, 2014, Precision announced first-quarter fiscal 2015 financial results2, which included a 1% sales growth in the Company’s investment cast segment over the first- quarter fiscal 2014 and a 2.8% sales growth in the Company’s forged products segment over the first- quarter fiscal 2014. According to the Complaint, first-quarter 2015 financial results missed consensus estimates. On this news, the price of Company shares declined $13.82 per share, or approximately 5.5%, from a close of $250.03 per share on July 23, 2014 to close at $236.21 per share on July 24, 2014. Then, on October 23, 2014, Precision announced its second-quarter fiscal 2015 financial results, which included a 4% sales growth in the Company’s investment cast segment over the second-quarter fiscal 2014 and a 3% sales growth in the Company’s forged products segment over the second quarter of fiscal 2014. According to the Complaint, the Company’s second-quarter 2015 financial results missed consensus estimates. On this news, the price of Company shares declined $6.88 per share over two trading days, or nearly 3%, from a close of $230.94 per share on October 21, 2014, to close at $224.06 per share on October 23, 2014. Finally, on January 15, 2015, Precision disclosed that third-quarter fiscal 2015 sales and earnings results would be “negatively impacted” by a combination of three primary factors that included: (1) lower customer demand; (2) “inventory management” by certain customers; and (3) “aerospace engine destocking” by a specific customer. On this news, the price of Company shares declined $20.09 per share, or more than 9%, from a close of $219.72 per share on January 15, 2015, to close at $199.63 per share on January 16, 2015. 1 The Individual Defendants named in the Complaint include: Mark Donegan (the Company’s Chairman and Chief Executive Officer); and Shawn Hagel (the Company’s Executive Vice President and Chief Financial Officer) 2 Precision’s 2015 fiscal year began on April 1, 2014. Q1  2016  11 UPDATES FOR ONGOING U.S. LITIGATION  The following list of ongoing litigation contains current updates for the past quarter. Please note: if there has been no new activity for this litigation during the quarter, the most recent status update is listed. Recently settled and dismissed cases are included in this section. A10 Networks, Inc. (2015)  Plaintiff filed a First Amended Consolidated Complaint on November 23, 2015. Mediation was scheduled for March  of 2016.  Accretive Health, Inc. (2013)  The court granted Preliminary Settlement Approval on March 8, 2016.  Baxter International Inc. (2010)  The court granted Final Settlement Approval on January 22, 2016.  Biogen Inc. (2015)  Lead Plaintiff filed an Amended Complaint on January 19, 2016, and on March 1, 2016, Defendants filed a Motion  to Dismiss.  ChannelAdvisor Corporation (2015)  On April 6, 2016, the court granted the Motion to Dismiss.  Cobalt International Energy, Inc. (2014)  On January 19, 2016, the court granted in part and denied in part Defendants’ Motion to Dismiss.  Corinthian Colleges, Inc. (2010)  On July 17, 2015, the court granted the dismissal of the appeal as to Corinthian Colleges only. The appeals shall  continue as to the remaining parties.  Covisint Corporation (2014)  The court granted Plaintiff's Motion to Certify Class on February 22, 2016.  CVS Caremark Corp. (2009)  The court granted Final Settlement Approval on February 17, 2016.  Cyan, Inc. (2014)  The parties have scheduled mediation to occur prior to June 15, 2016.  Diodes, Inc. (2013)  The USCA affirmed the Judgment of the District Court on February 4, 2016.   First Solar, Inc. (2012)  Defendants have filed an interlocutory appeal as to the loss causation issue in the Summary Judgment order.  General Motors Company (2014)  Lead Plaintiff filed for Final Settlement Approval on March 9, 2016.  Q1  2016  12 HCA Holdings, Inc. (2011)  Lead Plaintiff filed a Motion for Final Settlement Approval on March 7, 2016.  Imperva, Inc. (2014)  Plaintiff filed a Third Amended complaint on January 13, 2016, and on February 10, 2016, the Defendants filed a  Motion to Dismiss the Third Amended Complaint.  ITT Educational Services, Inc. (2013)  The court granted Final Settlement Approval on March 8, 2016.  JPMorgan Chase & Co. (2012)  The court granted Preliminary Settlement Approval on January 19, 2016.  Kohl's Corporation (2013)  Defendants' Motion to Dismiss, filed on June 12, 2015, is pending.  Medtronic, Inc. (2013)  Defendants filed a Motion to Dismiss the Amended Complaint on February 9, 2016.  Merck & Co., Inc. (2003)  The case is on appeal.  Microsoft Corporation (2013)  The case is on appeal.  NII Holdings, Inc. (2014)  On January 21, 2016, the parties notified the court that they have reached an agreement in principle to settle the  litigation. In light of this development, the court has stayed all pending litigation deadlines.  Orthofix International, N.V. (2013)  Lead Plaintiff filed a Motion for Final Settlement Approval on March 24, 2016.  Overseas Shipholding Group, Inc.  Lead Plaintiff filed a Motion for Final Settlement Approval and Plan of Allocation on November 3, 2015.  Petroleo Brasileiro S.A. (2014)  The case is in discovery.  PowerSecure International, Inc. (2014)  Defendants' Motion to Dismiss, filed on November 23, 2015, is pending.  Prudential Financial, Inc. (2012)  In February 2016, the parties engaged in court ordered mediation and reached an agreement to settle the  litigation.  Qualcomm Incorporated (2015)  The court appointed a Lead Plaintiff and Lead Counsel on February 19, 2016.  Rocket Fuel, Inc. (2014)  On February 1, 2016, Defendants filed an Answer to the Amended Complaint. Q1  2016  13 ONGOING NON‐U.S. LITIGATION  Opt‐in (active participant)  The following chart contains non-U.S. opt-in litigation you are already registered for. This chart only reflects those cases that Kessler Topaz assisted you in registering for. No action is currently required at this time. Kessler Topaz will notify you if there is any change to the status of the case, if any action is required on your part, or in the event the case reaches a resolution. AGEAS S.A./N.V. AND AGEAS N.V. (FKA FORTIS S.A./N.V. & FORTIS N.V.) (2011)  Netherlands  CLASS  DEFINITION  Investors who (1) relied on information published by Fortis when purchasing shares from May 29, 2007 through Oct. 14, 2008; (2) participated in the Company's September 2007 Rights Issue; or, (3) participated in Fortis' June 2008 Accelerated Book-Building Offer. STATUS In March 2016, a settlement of 1.2 billion Euros was announced. The settlement is currently pending approval by the court in Amsterdam. After the settlement is approved, investors will be able to file proof of claims and obtain a portion of the settlement proceeds. VOLKSWAGEN AG (EMISSIONS SCANDAL)  Germany  CLASS  DEFINITION  The securities of Volkswagen AG including common or preferred shares, and Porsche AG preferred shares, purchased or otherwise acquired during the period from June 6, 2008 through September 22, 2015. STATUS A complaint was filed in Braunschweig, Germany on March 14, 2016 on behalf of 278 institutional investors and alleging 3.2 billion Euros in investor damages. Volkswagen has not yet answered the complaint. We anticipate that the court will initiate model case proceedings under the KapMuG and appoint a model claimant before the fall of 2016. Given the interest in the case, Kessler Topaz and its partners are preparing to file a second complaint on behalf of institutional investors who were unable to join in time for the March 14th complaint. We are also looking to file claims for losses due to VW Bonds, derivatives, and Audi shares on behalf of investors who are part of the March 14th complaint. Q1  2016  14 ONGOING NON‐U.S. LITIGATION  Opt‐in (registration open)    The following chart contains active non-U.S. opt-in litigation for the last quarter. Registration is still open for these cases, and if you wish to share in the proceeds of any settlement or favorable judgment (should one result from these actions) you are required to affirmatively register and participate in the case before the listed deadline. Some of these actions are in the initial stages of being organized and given their preliminary stage, some of the currently advertised registration deadlines may be extended in the future. Kessler Topaz will continue to monitor these cases and will inform you of any changes to the registration deadline. Although some deadlines may be extended in the future, if you are interested in joining the action you should do so as soon as possible. If you have any questions or need any assistance with the registration process, please contact either Darren Check, Esquire: 610.822.2235 or Emily Christiansen, Esquire: 484.654.2890. TESCO PLC  (Kessler Topaz Meltzer & Check, LLP, Grant & Eisenhofer P.A., DRRT)  United Kingdom  CLASS  DEFINITION  On behalf of all shareholders who acquired shares in Tesco between January 1, 2012 and October 22, 2014 and who had not sold all of those securities prior to the announcement made by Tesco before the market opened on 29 August, 22 September or 23 October. STATUS There are currently multiple potential actions being investigated in the UK against Tesco. This particular action is being pursued by Kessler Topaz and its partners. Kessler Topaz and its partners have decided to hold off on litigation while facts develop. There is a long statue of limitations (6 years) in the UK and given the burden of proof and the fact that the UK authorities are still investigating, Kessler Topaz does not think it makes sense to immediately file litigation. Instead, Kessler Topaz and its partners have created a Dutch Foundation and will first attempt to resolve the case without litigation. The Foundation has also hired UK lawyers and is prepared to act immediately if and when the time comes. Kessler Topaz recommends all interested investors hold off on litigation for the time being and instead join this Foundation approach. Please contact Darren Check, Esquire or Emily Christiansen, Esquire to discuss this case and your options. ILUKA RESOURCES  LTD. (2014)  Australia    CLASS  DEFINITION  On behalf of all persons who acquired shares of Iluka Resources Ltd. (“Iluka”) between April 12, 2012 to July 8, 2012. STATUS This class action has not been filed yet but is anticipated that it will be filed soon. The lawyers for the plaintiffs sought pre-litigation discovery from Iluka but their application was denied. They appealed the decision denying their discovery request Q1  2016  15 and the appeals court will hear the discovery issue on February 25, 2016. At this time, investors may still register to join the action.   SAIPEM (2014)  (Kessler Topaz Meltzer & Check, LLP, Grant & Eisenhofer P.A., DRRT)  Italy  CLASS  DEFINITION  On behalf of all persons who acquired Saipem SpA (“Saipem”) common stock between January 2, 2007 and December 31, 2013. STATUS The group has filed three separate mediation requests with the Italian court. The third mediation request was filed on March 18, 2016 for a third group of institutional investors. A mediation hearing was scheduled for April 21, 2016 but it is likely that the hearing will be a mere formality in order to comply with requirements of Italian law because Saipem’s counsel made it clear at two previous mediation requests that they have no interest in mediating. If the hearing does not result in Saipem agreeing to mediation, the investor group will commence litigation and file a complaint in April or May. The claimant group that will be included in the group against Saipem in Italy will bring more than 200 Euros in claims.         Q1  2016  16 ONGOING NON‐U.S. LITIGATION  (opt‐out)     The following chart contains active non-U.S. opt-out litigation for the last quarter. Similar to U.S. class actions, you will be bound by the resolution of this case and will be eligible to share in the proceeds of any settlement or favorable judgment (should one result from these actions) unless you opt-out of the class. Those cases that were recently settled or dismissed are also included in this section, as indicated below. BARRICK GOLD CORPORATION (2014)  Canada  CLASS  DEFINITION  On behalf of all persons who acquired Barrick Gold Corporation ("Barrick") securities from May, 7 2009 to May 23, 2013. STATUS There are no developments to report.   MANULIFE FINANCIAL CORPORATION  (2009)  Canada  CLASS  DEFINITION  All persons/entities who acquired Manulife Financial Corporation ("MFC") common shares over the Toronto Stock Exchange or under a prospectus filed with a Canadian securities regulator during the Class Period and held the shares on February 12, 2009. STATUS This action is now in the discovery phase.   EXHIBIT E CLAIMS SUMMARY REPORT ABC Employees’ Retirement System December 31, 2015 $324,948.95 CLAIMS PAID IN 2015 SETTLEMENT CLASS PERIOD CLAIMS DEADLINE SETTLEMENT CHECK NUMBER DISTRIBUTION DATE SETTLEMENT CHECK AMOUNT Merck & Co., Inc. (2008)12/6/06 - 3/28/08 11/18/13 23266 1/30/15 $11,697.22 Schering-Plough Corp. (2008)1/3/07 - 3/28/08 11/18/13 33413 2/4/15 $6,230.80 VeriFone Holdings, Inc.8/31/06 - 4/1/08 1/29/14 105733 2/9/15 $175.71 Diamond Foods, Inc.10/5/10 - 2/8/12 1/9/14 26001065 3/12/15 $121.04 Toyota Motor Corporation 5/10/05 - 2/2/10 5/7/13 20043 3/17/15 $14.10 Medtronic, Inc. (2008)11/20/06 - 11/17/08 12/11/12 23697 4/10/15 $1,959.02 Enron (SEC)1/20/98 - 11/7/01 4/6/09 308529 4/28/15 $19.86 Internap Network Services Corp.5/3/07 - 8/5/08 12/4/13 2705 5/29/15 $421.56 Bain Capital Partners, LLC (Leveraged Buyout)Shares held at LBO date(s)12/29/14 001284 6/19/15 $79.17 Bank of America Corporation (2009) (Equity)9/18/08 - 1/21/09 4/25/13 373444 6/26/15 $4,044.06 Citigroup, Inc. (2007)2/26/07 - 4/18/08 2/7/13 192228 8/14/15 $203.79 Nomura Asset Acceptance Corp.7/22/05 - 1/31/08 12/26/13 300057 9/8/15 $355.52 Bain Capital Partners, LLC (Leveraged Buyout)Shares held at LBO date(s)12/29/14 40612 10/15/15 $19.73 Novatel Wireless, Inc.2/27/07 - 9/15/08 6/30/14 103460 12/2/15 $3,536.44 Recovery Awarded in 2015:$28,878.02 $353,826.97 PENDING CLAIMS SETTLEMENT CLASS PERIOD CLAIMS DEADLINE STATUS* Royal Dutch Shell US CLASS ACTION 4/8/99 - 6/15/04 11/18/08 TBD SiRF Technology Inc.6/21/07 - 3/25/08 11/13/09 Approved Carters Inc.3/16/2005 - 11/10/09 6/1/12 Approved Countrywide Financial Corp. (2010) (MBS Settlement)3/12/04 - 8/7/13 12/15/13 Partial Rejection Crocs, Inc.4/2/07 - 4/14/08 12/26/13 Approved American Superconductor Corporation 7/29/10 - 7/11/11 4/7/14 TBD Lehman Brothers Holdings, Inc. (Equity/Debt) (Ernst & Young)6/12/07 - 9/15/08 4/17/14 Partial Rejection Ebix, Inc.5/6/09 - 6/30/11 6/4/14 TBD Massey Energy Company (2010)2/1/08 - 7/27/10 7/3/14 Approved Genoptix, Inc.7/31/09 - 6/16/10 7/7/14 TBD Weatherford International Ltd.4/25/07 - 3/1/11 8/19/14 Approved Hansen Natural Corp. (n.k.a. Monster Beverage Corporation) (2008)11/9/06 - 11/8/07 11/12/14 TBD State Street Corp.10/17/06 - 10/21/09 12/16/14 TBD AMAG Pharmaceuticals, Inc. (2010)1/21/10 IPO 12/30/14 TBD Morgan Stanley Dean Witter Capital I (Morgan Stanley Issuing Trusts) Certificates defined in Settlement Notice 1/15/15 TBD Body Central Corp.11/10/11 - 6/18/12 1/26/15 TBD Total Recovery as of December 31, 2015: Total Recovery as of December 31, 2014: SETTLEMENT CLASS PERIOD CLAIMS DEADLINE STATUS* Ignite Restaurant Group, Inc.5/11/12 - 10/30/12 4/15/15 TBD WaMu Mortgage Pass-Through Certificates (2012) Certificates defined in Settlement Notice 4/20/15 TBD Uni-Pixel, Inc.12/7/12 - 5/31/13 4/22/15 TBD American International Group, Inc. (2008) 3/16/06 - 9/16/08 5/5/15 TBD St. Jude Medical, Inc.4/22/09 - 10/6/09 6/24/15 TBD Celera Corporation (2010)4/24/08 - 7/22/09 6/28/15 TBD Knight Capital Group, Inc.5/10/11-8/1/12 6/29/15 TBD RALI Mortgage (Asset-Backed Pass-Through Certificates) All Transactions 7/3/15 TBD RALI Mortgage (Asset-Backed Pass-Through Certificates) All Transactions 7/3/15 TBD Impax Laboratories, Inc. (2013)6/6/11 - 3/4/13 7/15/15 TBD Sprint Nextel Corp.10/26/06 - 2/27/08 7/20/15 TBD Allscripts Healthcare Solutions, Inc.11/8/10 - 4/26/12 7/22/15 TBD Pfizer Inc.1/19/06 - 1/23/09 7/30/15 TBD OmniVision Technologies, Inc.8/27/10 - 11/6/11 8/30/15 TBD Regions Financial Corporation 2/27/08 - 1/19/09 9/9/15 TBD PhotoMedex, Inc.11/6/12 - 11/5/13 9/10/15 TBD Delcath Systems, Inc.4/21/10 - 5/2/13 11/6/15 TBD IntraLinks Holdings, Inc. (2011)2/17/11 - 11/11/11 11/30/15 TBD Weatherford International Ltd. (2012)3/2/11 - 7/24/12 12/9/15 TBD The Bank of New York Mellon Corporation 2/28/08 - 10/4/11 12/11/15 TBD Impax Laboratories, Inc. (2014) 3/6/13 - 8/1/14 12/19/15 TBD Global Geophysical Services, Inc.2/22/12 - 3/26/14 12/21/15 TBD Tower Group International, Ltd. (2013) (Tower Defendants)3/1/10 - 12/17/13 12/28/15 TBD MGM Mirage 8/2/07 - 3/5/09 1/6/16 TBD Baxter International Inc.6/10/09 - 5/3/10 1/7/16 TBD Nortel Networks Corporation (SEC)10/24/00 - 4/27/04 3/16/12 Direct to Client REJECTED CLAIMS SETTLEMENT CLASS PERIOD CLAIMS DEADLINE STATUS Huron Consulting Group, Inc.4/27/06-7/31/09 (10/30/09)5/5/11 No Loss E*TRADE Financial Corp. (2007)4/19/06 - 11/9/07 10/31/12 No Loss Carter's Inc. (PWC)3/16/05 - 11/10/09 10/3/13 No Loss Johnson & Johnson (2010)10/14/08 - 7/21/10 12/24/13 No Loss Olympus Corporation 5/8/07 - 11/7/11 5/24/14 No Loss Textron Inc./Harman Fair Fund (SEC)4/9/09 and/or 7/20/09 6/30/14 No Loss Hospira, Inc.2/4/10 - 10/17/11 7/21/14 No Loss Hewlett-Packard Co. (2011)11/22/10 - 8/18/11 9/16/14 No Loss Autoliv, Inc.10/26/10 - 7/21/11 12/3/14 No Loss IndyMac Mortgage Pass-Through Certificates Certificates defined in Settlement Notice 1/28/15 Ineligible *Claims marked with an “Approved" status are subject to change status pending a final determination by the claims administrator and must meet the minimum payment threshold that has been approved by the Court to be eligible to receive a recovery. ABC EMPLOYEES' RETIREMENT SYSTEMAudit of Securities Class Action Settlement Claims due March 2014 - March 2016SETTLEMENT CLAIMS DEADLINE CLASS PERIOD ACCOUNT(S) ELIGIBLE TO FILEAmerican International Group, Inc. (2008) May 5, 2015 Mar 16, 2006 to Sep 16, 2008 52601ZX32Anadarko Petroleum CorporationNovember 8, 2014 Jun 12, 2009 to Jun 9, 2010 52601ZX28Audience, Inc. (2012)March 30, 2016 May 9, 2012 to Sep 13, 2012 52601ZX27Avon Products, Inc.January 19, 2016 Jul 31, 2006 to Oct 26, 2011 52601ZX32Barclays PLCMarch 21, 2016 Jul 10, 2007 to Jun 27, 2012 52601ZX28Career Education Corporation (2012)March 22, 2014 Feb 19, 2009 to Nov 21, 2011 52601ZX27Celera Corporation June 28, 2015 Apr 24, 2008 to Jul 22, 2009 52601ZX27China Ceramics Co., Ltd.December 30, 2015 Mar 30, 2012 to May 1, 2014 52601ZX32CRM Holdings, Ltd.March 18, 2015 Dec 21, 2005 to Nov 5, 2008 52601ZX27The Custodian for ABC Employees' Retirement System has confirmed that it is responsible for submitting proof of claim forms for all settlements in which ABC Employees' Retirement System is eligible to file. Kessler Topaz has reviewed a report of the claims filed by ABC Employees' Retirement System's Custodian during the two year audit period and has confirmed that claims for all settlements in which ABC Employees' Retirement System is eligible to file have been submitted. Based on a review of the available transaction history, Kessler Topaz has identified the below securities class action settlements with claims deadlines between March 2014 and March 2016 (the "two year audit period") in which ABC Employees' Retirement System purchased the relevant securities during the Class Period and met the eligibility requirements to file a claim. Please be advised that meeting the eligibility requirements to file a claim does not guarantee that the claim will be eligible to receive a recovery under the Court approved plan of allocation. SETTLEMENT CLAIMS DEADLINE CLASS PERIOD ACCOUNT(S) ELIGIBLE TO FILEDeer Consumer Products, Inc. (2013)January 18, 2016 Mar 31, 2009 to Aug 10, 2012 52601ZX32Global Geophysical Services, Inc.December 21, 2015 Feb 22, 2012 to Mar 26, 2014 52601ZX35iBio, Inc.March 7, 2016 Oct 6, 2014 to Oct 23, 201452601ZX2752601ZX32IntraLinks Holdings, Inc. November 30, 2015 Feb 17, 2011 to Nov 11, 2011 52601ZX28Kinder Morgan Energy Partners, L.P.December 26, 2015 Feb 5, 2011 to Nov 26, 2014 52601ZX27Metrologic Instruments, Inc.March 1, 2014 Sept 12, 2006 to Dec 21, 2006 52601ZX24MiMedx Group, Inc.January 18, 2016 Mar 29, 2012 to Sep 4, 2013 52601ZX32NeuStar, Inc.February 3, 2016 Apr 19, 2013 to Jun 6, 2014 52601ZX28OSI Systems, Inc.January 15, 2016 Jan 24, 2012 to Dec 6, 2013 52601ZX32Questcor Pharmaceuticals, Inc.September 2, 2015 Apr 4, 2011 to Sep 21, 2012 52601ZX28Silvercorp Metals, Inc.February 4, 2015 May 20, 2009 to Sep 13, 2011 52601ZX32Tibet Pharmaceuticals, Inc.January 11, 2016 Jan 24, 2011 to Apr 3, 2012 52601ZX28Triad Guaranty, Inc.March 21, 2016 Oct 26, 2006 to Apr 1, 2008 52601ZX28UniTek Global Services, Inc.July 11, 2014 May 18, 2011 to Apr 12, 2013 52601ZX27Yuhe International, Inc.July 31, 2014 Dec 31, 2009 to Jun 17, 2011 52601ZX25Zynga, Inc. (N.D.Cal)March 11, 2016 Dec 15, 2011 to Jul 25, 2012 52601ZX28 SUGARMAN & SUSSKIND PROFESSIONAL ASSOCIATION ATTORNEYS AT LAW Robert A. Sugarman♦ 100 Miracle Mile Howard S. Susskind Suite 300 Kenneth R. Harrison, Sr. Coral Gables, Florida 33134 D. Marcus Braswell, Jr. (305) 529-2801 Pedro A. Herrera Broward (954) 327-2878 Ivelisse Berio LeBeau Toll Free 1-800-329-2122 Dustin L. Watkins Facsimile (305) 447-8115 ♦Board Certified Labor & Employment Lawyer LEGISLATIVE UPDATE And ACTION PLAN June 2017 SENATE BILL 80 – AMENDMENTS TO THE PUBLIC RECORDS ACT On May 23, 2017, Governor Rick Scott signed into law Senate Bill 80, a bill intended to curb what some consider abuses of Florida’s broad public records law. This law responds to the practice of filing so-called “gotcha” lawsuits in which members of the public file frivolous public records requests intended primarily to cause a violation of the law and result in an attorney fee award. This law applies to all public records requests made on or after May 23, 2017. The public records law states that when a member of the public sues a public agency to obtain public records because those records were not produced accordingly, the person suing the agency is entitled to an award of attorney fees and costs associated with the lawsuit. Senate Bill 80 creates a new requirement that a member of the public who seeks an award of attorney fees and costs must provide written notice to the agency’s custodian of public records no less than five business days before filing the lawsuit. The five-day notice is not required if the agency does not prominently post contact information for the agency’s custodian of public records in the agency’s primary administrative building and on the agency’s website. The new law also permits a court to award attorney fees and costs to the public agency if the court determines that a public records lawsuit was initiated for an “improper purpose.” An improper purpose is defined as a frivolous request to inspect or copy a public record or a public record request initiated for the purpose of causing a violation of the public records law. As noted above, the new law provides a means of reducing the risk of an adverse attorney fee award by prominently posting contact information for the custodian of public records. This notice must be prominently posted both in the agency’s primary administrative building and on the agency’s website, if the agency has a website. “Primary administrative building” is defined as the place where public records are routinely created, sent, received, maintained, and requested. For a local law retirement system, this will be Legislative Update & Action Plan June 2017 Page | 2 wherever most retirement system business is conducted, such as a pension fund office, a municipal building, a special district office, or the offices of a third party administrator. Action Plan To take advantage of the five-day notice requirement, we recommend all clients take the following actions: 1. Identify who will serve as the custodian of public records. This should be the person who routinely deals with public records and regularly interfaces with plan participants and the public, such as an administrator or a trustee. 2. Identify the “primary administrative building.” This may be the retirement system’s own offices, if it has any. Otherwise, this will be wherever the retirement system conducts most of its business, whether it be a municipal building, a special district office, or the offices of a third party administrator. 3. Prepare a notice. The notice must describe how to contact the custodian of public records. A sample notice is enclosed with this legislative update. 4. Post the notice. This notice should be posted in the primary administrative building in a prominent place, such as a bulletin board. If the agency has a website, the notice must be posted on the website as well. Some third party administrators maintain websites for their clients. We recommend that the notice be posted on those websites as well. SENATE BILL 7022 – REVISIONS TO FLORIDA RETIREMENT SYSTEM This legislative session also included several changes to FRS. Senate Bill 7022, which passed on May 8, 2017, provides that new workers who join FRS will automatically enter the FRS Investment Plan (i.e., the defined contribution plan) rather than the FRS Pension Plan (i.e., the defined benefit plan). Although new workers automatically enroll in the FRS Investment Plan, they may, within eight months of initial hire, make a one-time irrevocable election to enter the FRS Pension Plan. New workers who are considered “Special Risk Class members” will continue to automatically enroll in the FRS Pension Plan. The new law also allows retirees of the FRS Investment Plan who are reemployed in covered service to become renewed members of the FRS Investment Plan. Renewed membership is not permitted, however, for a retiree of the FRS Pension Plan. The new law also provides that a line-of-duty death survivor benefit is payable to the surviving child of a Special Risk Class member who died in the line of duty on or after July 1, 2002. These changes do not affect local law retirement systems. [INSERT: NAME OF RETIREMENT SYSTEM] ALL NOTICES AND REQUESTS UNDER THE PUBLIC RECORDS LAW, CH. 119, FLA. STAT., SHOULD BE DIRECTED TO THE CUSTODIAN OF PUBLIC RECORDS AS FOLLOWS. 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