In re SLM Corp. Securities Litigation
This Memorandum and Order addresses the appointment of a lead plaintiff in a securities class action against SLM Corporation. Initially, Westchester Capital Management, Inc. was appointed, but its Article III standing was questioned following a Second Circuit ruling in W.R. Huff Asset Mgmt. v. Deloitte & Touche LLP, which clarified that investment advisors without a valid assignment of claims lack standing. The court denied Westchester Capital's subsequent motion to approve a post-appointment assignment, reasoning it would not cure the initial lack of standing and presented unique legal issues for the class. Consequently, the court considered other movants for lead plaintiff, ultimately appointing SLM Venture, a joint venture with the largest financial interest, finding it satisfied the typicality and adequacy requirements under the PSLRA and Rule 23. Girard Gibbs & De Bartolomeo, LLP was approved as lead counsel for SLM Venture.