Securities Law Alert
In This Edition:• First Circuit: Disclosure of FDA Concerns Undercuts Any Inference of Scienter• Eighth Circuit: Affirms the Dismissal of a Securities Fraud Action Against a Major Retailer for Failure toAllege Scienter• Southern District of New York: Underwriting a Tranche of Securities Does Not Subject the Underwriter to
Section 11 Liability for the Entire Securitization• Southern District of New York: Plaintiffs Adequately Pled a Securities Fraud Claim Based on an Alleged
Violation of Item 303 of Regulation S-K• Southern District of New York: Plaintiffs Must Allege “How and Why” an Alleged Misstatement Was False
and Misleading at the Time It Was Made
• Southern District of New York: Disclosures Concerning the Possibility That Problems Might Arise Are
Insufficient If Those Problems Have Already Occurred• Southern District of New York: The “Mere Existence” of Reports of Adverse Pharmaceutical Events Is Not
Material, Standing Alone
April 2020

First Circuit: Disclosure of
FDA Concerns Undercuts Any
Inference of Scienter
Simpson Thacher’s“work is top-notch”
and the Firm is “vastly
experienced in complex
litigation.”–Chambers USA(quoting a client)

Simpson Thacher & Bartlett LLPOn April 9, 2020, the First Circuit affirmed
the dismissal of a securities fraud action
alleging that a biopharmaceutical company
failed to disclose “material facts about [thecompany’s] manufacturing problems and theimpact those problems were likely to have on
the FDA’s approval” of the company’s ocular
pain drug. Mehta v. Ocular Therapeutix,
2020 WL 1808366 (1st Cir. 2020) (Stahl,
C.J.). The First Circuit found it significant that
defendants fully disclosed the FDA’s concerns
regarding certain manufacturing issues. The
court held that these disclosures belied any
inference of scienter.

Plaintiffs challenged statements in thecompany’s 2016 and 2017 Forms 10-K
representing that the company manufactured
its ocular pain drug “using current Good
Manufacturing Practices [cGMP]”, as wellas an executive’s May 2017 statements
describing the company’s drug manufacturing
process as “fully developed.” Plaintiffs argued“that a strong inference of scienter can be
drawn from those alleged misstatements
because defendants made them despite
having received” Forms 483 from the
FDA in February 2016 and May 2017 that“apprised defendants of [the company’s]
manufacturing problems.”
The First Circuit held that plaintiffs’“allegations do not give rise to a strong
inference of scienter.” The court noted thatthe 2016 and 2017 Forms 10-K “disclosedreceipt of the February 2016 Form 483,
described its relevance to [the company’s]
manufacturing capabilities, and warned of
its implications.” The 2016 and 2017 Forms
10-K also specifically warned investors that
resolution of the issues identified in the
February 2016 Form 483 was a prerequisite
for FDA approval. The First Circuit found“[t]hese informative disclosures about thenature and consequences of the February
2016 Form 483 undercut any inference
that defendants intentionally or recklessly
misled investors” concerning the company’s
compliance with cGMP regulations. Rather
than inferring scienter, the court determinedthat “the more reasonable inference ofnonfraudulent intent is that defendants
were [simply] stating their intention tocomply with cGMP regulations as thegoverning standards for their drug productmanufacturing operations.”from the complaint’s allegations is that [theexecutive] spoke with nonfraudulent intent
in describing [the company’s] manufacturing
process as ‘fully developed.’”Eighth Circuit: Affirms theDismissal of a Securities
Fraud Action Against a Major
Retailer for Failure to Allege
ScienterOn April 10, 2020, the Eighth Circuit affirmed
the dismissal of a securities fraud action
alleging that a major retailer and several of its
executives made misstatements concerning
the company’s ultimately unsuccessful foray
into the Canadian market. In re Target Corp.
Sec. Litig., 2020 WL 1814268 (8th Cir. 2020)(Kobes, C.J.). The Eighth Circuit determinedthat “[n]othing in the complaint makes a‘compelling’ case for fraud.” Rather, the court
found “the more compelling inference” is thatthe company’s executives “did not understandthe magnitude of the problems they faced”
with the Canadian stores.

Background

As to the May 2017 statements concerning
the “fully developed” nature of the company’s
manufacturing processes, the First Circuit
noted that a company executive specificallydisclosed the receipt of a Form 483 fromthe FDA one day earlier and discussed its
ramifications. The First Circuit found thatthese disclosures “made pellucid that [thecompany’s] manufacturing process wasconsidered deficient by the FDA.” The court
also credited defendants’ representationthat in the FDA approval context, the phrase“fully developed” refers to a process that “hassurpassed the concept or piloting stage but
must still be tested and validated to determine
whether the process works as intended andmeets the necessary standards.” The court
determined that “[i]n light of that term of art
and [the executive’s] disclosures during theconference call that contravene[d] plaintiffs’
characterization of his statements, the morereasonable and compelling inference drawn

Between March and November of 2013, thecompany opened 124 new stores in Canada,
and also “developed new supply chain andinformation technology infrastructure to
support them.” The company’s “decision
to develop these new systems proved
disastrous,” as its “new inventory forecasting
software provided inaccurate demand
forecasts and employees did not understandhow to use it.” The company’s “other systems
compounded these problems,” leading to“some shelves sitting empty and others
overflowing with inventory.” In January 2015,
the company “announced plans to shutter
its Canadian stores.” Plaintiffs subsequently
brought suit alleging that defendants “misledinvestors by understating the seriousnessof the problems with” the company’s
Canadian operations by “overstating theirability to correct” the problems and “making
unrealistic projections about the profitabilityof the Canadian stores.” The court granted
defendants’ motion to dismiss, andplaintiffs appealed.

2Plaintiffs Failed to Allege that the
Individual Defendants Knew theStatements Were False When Made
The Eighth Circuit found that “none” ofplaintiffs’ allegations satisfied the scienter
requirement. For example, plaintiffs
challenged a March 2013 statement by
the company’s CFO representing that thecompany had achieved “all” of its “objectives”
with respect to building the technology for
its Canadian operations. Plaintiffs contended
that at the time the CFO made this statement,
defendants knew or recklessly disregarded“systemic problems . . . in [the company’s]
supply chain IT systems.” The Eighth Circuit
noted that plaintiffs offered “no particularized
explanation of how or when [the company’s]
executives learned this statement was false.”
The court emphasized that it “disregard[s]‘blanket’ or ‘catch-all’ assertions of scienter.”
Plaintiffs also challenged statements
representing that the company was “tuning”
its Canadian technology systems, on the
grounds that defendants “actually knew more
drastic action was needed.” The Eighth Circuit
found that the complaint did “not show” thatthe executives were aware that their “tuning”
efforts would fail, and emphasized that thePrivate Securities Litigation Reform Act(“PSLRA”) “does not allow pleading fraud
by hindsight.”
The Eighth Circuit found that “[t]he strongest,but still insufficient, allegation” concerned thecompany’s May 2014 representation that thelonger the Canadian stores had been open, thebetter they were performing. Plaintiffs allegedthat defendants must have known that thisstatement was false because in August 2014,
the company “revealed that same-store sales
had fallen more than 11% in Canada over theprevious year.” The Eighth Circuit stated that“financial deterioration alone is not enoughto show fraud.” The court explained that “theapparent incongruity” between the May 2014
statement and the August 2014 financial
results was not sufficient to “show that the
May 2014 statement was necessarily false,
let alone that [company] executives knew it
was false.”

The Individual Defendants’ Stock
Sales Did Not Give Rise to an
Inference of Scienter
The Eighth Circuit also found defendants’stock sales insufficient to raise an inferenceof scienter. The court explained that while“insider stock sales can be probative ofmotive, they are not inherently suspicious andbecome so only when the level of trading is
so dramatically out of line with prior trading
practices at times calculated to maximize
the personal benefit from undisclosed inside
information.” In the case before it, plaintiffs“allege[d] that the individual defendants
sold 10-20% of their shares during the classperiod.” The court noted that it has “foundsales of up to 32% of an individual’s stock notinherently suspicious.” The court also foundit significant that “[t]he bulk of the sales weremade early in the class period and provide
no motive for defrauding investors in thefollowing months.”

The District Court Did Not Err in
Denying Leave to Amend
The Eighth Circuit found “no abuse of
discretion” in the district court’s denial ofplaintiffs’ motion for leave to amend. The
Eighth Circuit noted that while “the amended
complaint added color and detail to theinvestors’ allegations, it still failed to allege
that [company] executives knew that they
were making false statements.” The Eighth
Circuit found that the new allegations in
the amended complaint were “perfectly
consistent with the narrative that [thecompany] had serious problems that none ofits executives understood.”3Southern District of New
York: Underwriting a Trancheof Securities Does Not Subject
the Underwriter to Section
11 Liability for the Entire
Securitization
On March 11, 2020, the Southern Districtof New York held that the underwriter of
one tranche of securities was not subject toliability under Section 11 of the Securities
Act of 1933 (“Securities Act”) with respect
to a different tranche of securities from thesame securitization that it did not underwrite.
Federal Deposit Ins. Corp. v. First Horizon
Asset Securities, 2020 WL 1165848 (S.D.N.Y.
2020) (Stanton, J.).1 The court granted theunderwriter’s motion for summary judgmenton the Section 11 claim.
The court rejected plaintiff’s contention that adefendant’s “liability as an underwriter is not
limited to the tranche or class of subordinatedcertificates” that the defendant actually
underwrote. The court explained that “theright to sue that Section 11 gives a purchaserof a security is to sue ‘every underwriter withrespect to such security,’ or underwriters of
the security at issue.” Id. (quoting 15 U.S.C.
§ 77k(a)). The court held that this “right does
not encompass suing every underwriter withrespect to the entire securitization and each ofits securities.”
The court also found meritless plaintiff’s
alternative argument that even though thedefendant underwriter “did not directly
purchase or sell the senior certificates” atissue, the defendant was nonetheless subject
to Section 11 liability “because of its ‘direct
or indirect participation’ in the distributionof the senior certificates.” Id. (quoting 15
U.S.C. § 77b(a)(11)). The court recognized that“[p]ersons may be liable [under Section 11] forparticipation [in the distribution of securities]
even though they did not themselves directlysell or offer securities or purchase securities
for resale.” Id. (quoting In re Lehman Bros.
Mortg.-Backed Sec. Litig., 650 F.3d 167 (2dCir. 2011)). However, the court emphasizedthat Section 11 does not reach “persons who
provide services that facilitate a securities
offering, but who do not themselves
participate in the statutorily specified
1. Simpson Thacher represented NatWest Markets Securities
Inc. (f/k/a RBS Securities Inc.) in this matter.

distribution-related activities.” Id. (quoting
Lehman Bros., 650 F.3d 167).
Here, plaintiff asserted that the defendant“participated in the distribution of the[senior] certificates by performing due
diligence on the loans backing the certificatesin the securitization” and reviewing theprospectus supplements. Plaintiff contended
that “[b]ecause many of the loans backing
the senior certificates are the same as thosebacking the subordinated certificates” thatthe defendant underwrote, the defendant’s“contribution to the securitizations was not
limited to the subordinated certificates.” Thecourt held that while the defendant’s efforts“helped facilitate the securities offerings,
those activities do not involve the purchase,offer, or sale of the securities and are thus notpart of their distribution.”
Plaintiff also argued that the seniorcertificates “would never have been offeredwithout [the defendant’s] participation”
because “the collateral underlying thesubordinate certificates, and the credit
protection they provided, was material
to investors” who purchased the seniorcertificates. The court held that “[e]ven if
those statements are true, those relationships
are not part of the purchase, offer, or sale ofthe senior certificates.”
The court concluded that “there is no
genuine issue whether [the defendant] is anunderwriter of the senior certificates at issue;
it is not.”Southern District of New
York: Plaintiffs Adequately
Pled a Securities Fraud Claim
Based on an Alleged Violationof Item 303 of Regulation S-K
On April 14, 2020, the Southern Districtof New York held that plaintiffs “alleged aplausible securities fraud claim premised ona violation of Item 303” of Regulation S-K.
Plumbers & Pipefitters Nat’l Pension Fundv. Davis, 2020 WL 1877821 (S.D.N.Y. 2020)(Woods, J.). “Item 303 requires a publiccompany to describe in its Forms 10-K or
10-Q ‘known trends or uncertainties’ thatthe company ‘reasonably expects will havea material favorable or unfavorable impact
4

on net sales or revenues or income fromcontinuing operations.” Id. (quoting 17 C.F.R.
§ 229.303(a)(3)(ii)). The court stated that if aviolation of Item 303 “is adequately alleged,
it can give rise to liability under Section 10(b)because Item 303 creates a legal disclosure
obligation with which a regulated company
must comply.”2
In the case before it, plaintiffs alleged thata manufacturer of sports equipment andapparel “flooded the market with discounted
inventory to increase its short-run sales
figures.” Plaintiffs further alleged that“partially as a result of [d]efendants’ sales
practices, there was a marked increase
in inventory of unsold [ ] goods at [thecompany’s] retailers.” Plaintiffs “argue[d]that [the company’s] practice of flooding
the market with inventory far in excess ofdemand was a trend that required disclosure”
under Item 303.
The court found plaintiffs “adequately
alleged that [the company’s] sales practices
created a trend of increasing inventory,” anddetermined that “[i]t was both reasonably
foreseeable and material to [the company’s]
future performance that a buildup of
inventory would lead to a decline in [thecompany’s] future sales.” The court further
held that plaintiffs’ allegations “create[d] aplausible inference that [d]efendants had
actual knowledge of this trend because
they received repeated warnings that [thecompany’s] sales tactics were cannibalizing
future sales.” The court concluded thatplaintiffs “adequately pleaded” a securities
fraud claim based on a violation of Item 303.
The court further held that plaintiffs
adequately alleged misstatements regarding
the sources and nature of the company’ssales growth, as well as potential risks to thecompany. The court found that “[b]ecause[d]efendants specifically cited their strategy
as a source of their success, they were
obligated to tell the whole truth with respect
to that strategy by disclosing that their sales
growth was, at least in part, the result of
short-run sales tactics that led to a buildup
of inventory at [the company’s] customers.”
2. The court cited to Stratte-McClure v. Morgan Stanley, 776
F.3d 94 (2d Cir. 2015). In Stratte-McClure, the Second Circuit
held that “a violation of Item 303’s disclosure requirements
can only sustain a claim under Section 10(b) and Rule 10b-5
if the allegedly omitted information satisfies Basic’s test formateriality.” Please click here to read our discussion of theSecond Circuit’s decision in Stratte-McClure.

The court further found that defendants’disclosures regarding the risk of “inventory
levels in excess of consumer demand” werefalse or misleading because defendants
allegedly “had actual knowledge that [thecompany’s] customers already had excessive
levels of inventory” at the time they madethose statements.

Southern District of New
York: Plaintiffs Must Allege“How and Why” an Alleged
Misstatement Was False andMisleading at the Time It Was
Made
On April 2, 2020, the Southern District of
New York dismissed a securities fraud action
because plaintiffs failed to “show how andwhy” defendants’ alleged misstatements werefalse and misleading at the time they were
made. In re Adient plc Sec. Litig., 2020 WL
1644018 (S.D.N.Y. 2020) (Abrams, J.). The
court underscored that “simply stating thatthe statements are false is not enough” tostate a securities fraud claim.
Plaintiffs alleged that defendants mademisstatements regarding the company’s
progress towards its projected margin
expansion, as well as improvements inthe company’s metals business. The court
noted that “[t]he underlying premise of theallegations regarding both sets of statements
is that [d]efendants failed to disclose certain
operational issues that existed within the[m]etals business.” Plaintiffs suggested thatthe company’s “projected margin expansion
was not achievable” because of these issues.
The court found plaintiffs’ allegations
insufficient to plead actionable misstatements.
The court observed that “[d]efendants
5repeatedly made it clear that improvements in
the [m]etals business was just one componentof the projected margin expansion.” The court
found that “even if it is true that [m]etals was
not achieving certain specific improvements,
such a finding does not lead to the conclusionthat [the company’s] overall projected margin
expansion or plan to improve [m]etals ingeneral was ‘unreasonable’ or ‘unrealistic’—letalone false—at the time statements about it
were made.”
The court also found that “[p]laintiffs seemto conflate [d]efendants’ statements aboutprogress towards the projected margin
expansion, on the one hand, and progressin improving the [m]etals business, on theother.” The court pointed out that “[v]irtually
all of the challenged statements in the[complaint] about the [c]ompany being ‘ontrack’ were made in the context of the overall
projected margin expansion, and did notconcern specific improvements in the [m]etals
division.” The court found that it was “entirely
possible that, at the time these statements
were made, [the company] was ‘on track’ toreach its projected margin expansion at somepoint in the future, regardless of any specificoperational issues that may have existed in[m]etals at the time.”
The court noted that many of the statements
at issue were subjective statements of opinion
regarding the company’s progress towards
the margin expansion. Plaintiffs’ “theory of
liability as to these opinion statements isthat [d]efendants allegedly failed to disclose
underlying facts that directly contradicted
those statements.” But the court found thatthe complaint “does not plausibly allege
any specific material facts—omitted from[d]efendants’ statements—that rendered theopinion statements false or misleading to areasonable investor.” The court observed that
defendants in fact “publicly acknowledgedthat [m]etals needed ‘fixing’” and “disclosed
specific operational issues in the [m]etals
business as they arose.”
The court also found that many of thestatements at issue were forward-looking
within the meaning of the PSLRA, eventhough they included both present andfuture statements. The court explainedthat “when the present-tense portion of
mixed present and future statements does
not provide specific information about thecurrent situation, but merely says that,whatever the present situation is, it makes
the future projection attainable, the present
tense portion of the statement is too vague
to be actionable apart from the future
projection.” The court found “statementsthat the [c]ompany was ‘on track’ to reachthe projected margin expansion and related
growth” were “too vague to be actionable
apart from the future projection,” as they
“provide no specific information as to [thecompany’s] current circumstances.”

Southern District of New
York: Disclosures Concerning
the Possibility That Problems
Might Arise Are Insufficient If
Those Problems Have AlreadyOccurred
On March 30, 2020, the Southern Districtof New York held that plaintiffs adequately
alleged claims under Sections 11 and 12(a)(2)of the Securities Act of 1933 based on
misstatements concerning the termination ofexperienced employees and the integration of
acquisitions. City of Omaha Police & Fire Ret.
Sys. v. Evoqua Water Techs. Corp., 2020 WL
1529371 (S.D.N.Y. 2020) (Nathan, J.).3 The
court found defendants warned of problems
that could potentially occur, when in fact the
problems had allegedly already occurred.
Plaintiffs alleged that the company had
adopted “a policy or practice” of cutting costsby replacing experienced sales employeeswith “far less experienced (and less qualified
and effective) employees.” Plaintiffs
contended that the company “strong-armed
many employees into retirement by, forexample, “setting impossible-to-meet quotas.”
Plaintiffs asserted that the loss of experienced
employees “had a significant adverse impact
on the business.” Defendants responded thatthe company had disclosed the initiation of a
“Voluntary Separation Plan” that “include[d]severance payments to employees as aresult of streamlining business operations
for efficiency.” The company also warned
3. “Section 11 of the Securities Act imposes liability on issuers
and other signatories of a registration statement that‘contained an untrue statement of a material fact or omitted
to state a material fact required to be stated therein ornecessary to make the statements therein not misleading.’”
Evoqua, 2020 WL 1529371 (quoting 15 U.S.C. § 77k(a)).
“Section 12(a)(2) provides similar redress where the securities
at issue were sold using prospectuses or oral communications
that contain material misstatements or omissions.” Id.
6

that the “failure to retain” sales personnel“could materially adversely impact [its]ability to operate or grow [its] business.” Thecourt found these disclosures inadequate
because “[d]efendant’s disclosures . . . werehypothetical” yet “the risks disclosed by[d]efendants had already materialized.” Thecourt emphasized that “[w]arning of risks
that could occur at some future date does notwarn investors that those risks have alreadycome to pass.”‘success’ can be puffery.” But in the statement
at issue, “the word [success] modifies aparticular noun—acquisition and integration
capabilities.” The court found that whenread “in context,” this statement “represents
that [the company] has demonstrated thesecapabilities successfully.” The court held thatit could not “conclude that no reasonable
investor would rely on this statement, andthus [the] puffery doctrine cannot defeat[p]laintiffs’ claim at this stage of litigation.”

Southern District of New
York: The “Mere Existence”
of Reports of Adverse
Pharmaceutical Events Is Not
Material, Standing Alone

Plaintiffs also alleged that defendants mademisstatements “regarding [the company’s]
acquisitions and efforts at integrating thosecompanies into its operations.” Plaintiffs
asserted that the company failed to disclosethat it “terminated the staff members
responsible for integration” and “faced
serious problems in integrating one of its newacquisitions.” Defendants argued that thecompany specifically cautioned that it “mayhave difficulty in operating or integrating any
acquired businesses, assets, or product lines
profitably.” The court found this warning
insufficient because plaintiffs alleged that“at the time that statement was made,” thecompany “had already fired integration staff”
and the integration of one acquisition “wasalready going poorly.” The court underscoredthat “[a] hypothetical disclosure about
potential future problems is . . . not curative”
if the problems had already occurred at thetime of the alleged misstatements.
Defendants also argued that certain of
its statements were inactionable puffery.
For example, defendants pointed to thecompany’s statement that “[o]ur management
team has also expanded our operations to
new target markets and geographies and has
demonstrated successful acquisition andintegration capabilities.” The court recognizedthat “a representation that something is a

On March 26, 2020, the Southern District of
New York dismissed a securities fraud action
alleging that a pharmaceutical company failed
to disclose certain serious adverse events(“SAEs”) experienced by patients using thecompany’s liver disease drug. Liu v. Intercept
Pharms., 2020 WL 1489831 (S.D.N.Y. 2020)(Kaplan, J.). The court recognized that“[a]dverse events are material when there isa scientifically reliable basis for inferring a
potential causal link between the drug and theadverse event.” But the court emphasized that“[t]he mere existence of reports of adverse
events is not material.” Rather, “[s]omething
more is needed.”
At issue in the case before it were reports that
27 out of 3,000 patients—or less than 1% ofusers—experienced one or more SAEs during
the one-year long class period. The SAEs
consisted of “nineteen deaths and elevencases of serious liver injury.”4 Plaintiffs argued
that they “sufficiently [had] pled ‘somethingmore’” by pointing to factors such as “theFDA’s historic concern with liver injuries”; an
FDA investigation into the SAEs commenced
after the company announced that a patientin its Phase 2 trial had died; and “the FDA’sconcerns about the ‘vulnerabilities’” of certain
very sick patients and “the known need forthese patients to receive a lower dose” ofthe drug.
The court found these factors insufficient todemonstrate the materiality of the SAEs. The
court explained that liver damage “is a known
4. Three patients suffered liver injuries prior to their deaths.
7

complication of most prescribed drugs.” Thecourt also found that FDA actions taken after
the disclosure of an SAE did not demonstrate
the materiality of the SAEs that were notpreviously disclosed. The court reasoned thatplaintiffs “falsely equate[d] FDA action taken
after the statements at issue were made withwhether adverse events were material under
the securities laws at the time the statements
were made.” The court also found that “[t]othe extent that there were concerns about
the vulnerabilities of late-stage patients,”
these concerns did not support a finding ofmateriality because “these patients ha[d]compromised livers and already were quite

sick.” The court emphasized that “someadverse events may be expected to occur
randomly, especially with a drug designed totreat people that are already ill.”
The court observed that “[w]hen plaintiffs’
argument is stripped of its allegations of‘something more,’ they are left only with theoccurrence of serious liver injury or death infewer than 1 percent” of patients. The court
found that these allegations “[fell] short”
of adequately pleading that a “reasonable
investor would have viewed the thirty
reported SAEs as significantly altering thetotal mix of information available.”This edition of the
Securities Law Alert was edited by
Susannah S. Geltman
sgeltman@stblaw.com / +1-212-455-2762,
Paul C. Gluckow
pgluckow@stblaw.com / +1-212-455-2653,
and Linton Mann III
lmann@stblaw.com / +1-212-455-2654.

8

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Los Angeles

Brooke E. Cucinella+1-212-455-3070
brooke.cucinella@stblaw.com

Joseph M. McLaughlin+1-212-455-3242
jmclaughlin@stblaw.com

Chet A. Kronenberg+1-310-407-7557
ckronenberg@stblaw.com

Paul C. Curnin+1-212-455-2519
pcurnin@stblaw.com

Lynn K. Neuner+1-212-455-2696
lneuner@stblaw.com

Palo Alto

Stephen M. Cutler+1-212-455-2773
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Michael J. Osnato, Jr.
+1-212-455-3252
michael.osnato@stblaw.com

Michael J. Garvey+1-212-455-7358
mgarvey@stblaw.com

Alan C. Turner+1-212-455-2472
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Susannah S. Geltman+1-212-455-2762
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David Elbaum
Senior Counsel+1-212-455-2861
david.elbaum@stblaw.com

Joshua A. Levine+1-212-455-7694
jlevine@stblaw.com
Linton Mann III+1-212-455-2654
lmann@stblaw.com

Janet A. Gochman
Senior Counsel+1-212-455-2815
jgochman@stblaw.com

Stephen P. Blake+1-650-251-5153
sblake@stblaw.com
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jkreissman@stblaw.com
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Senior Counsel+1-650-251-5203
sstrauss@stblaw.com

Washington, D.C.
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+1-202-636-5532
jeffrey.knox@stblaw.com
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cscarboro@stblaw.com

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Adam Goldberg+852-2514-7552
adam.goldberg@stblaw.com

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