In Re Enron Corporation Securities, Derivative
This multidistrict litigation involves claims against the Outside Directors of Enron Corporation following its collapse. Plaintiffs, including various Ohio Retirement Systems, alleged negligent misrepresentation, aiding and abetting common law fraud, and violations of Section 18 of the Securities Exchange Act of 1934. The Outside Directors sought to dismiss all claims, arguing that Rule 9(b) heightened pleading standards applied and that claims were time-barred. The court granted dismissal for the aiding and abetting common law fraud claims but denied it for Section 18 and negligent misrepresentation, providing plaintiffs 30 days to amend their pleadings to meet particularity requirements for actual reliance and fraudulent intent, given the complexity of the alleged fraud. The court also clarified that outside directors who signed SEC-filed documents containing misrepresentations may be liable under Section 18.