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A recent Third Circuit opinion demonstrates the high bar that plaintiffs face when attempting to plead the falsity of two categories of statements: (1) risk factors alleged to be misleading because the warned-of risk had already materialized, and (2) forward-looking earnings projections. In Williams v. Globus Medical, Inc., — F.3d —, 2017 WL 3611996 (3rd Cir. Aug. 23, 2017), the Third Circuit affirmed a district court ruling dismissing such claims.
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