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Securities Regulation, Keyed to Choi
Goldman Sachs Group, Inc. v. Arkansas Teacher Retirement System
Citation:
141 S.Ct. 1951, 594 U.S. 113 (2021)Facts
Arkansas Teacher Retirement System and other pension funds brought a securities fraud class action against Goldman Sachs Group, Inc., and three former executives, alleging violations of Section 10(b) and Rule 10b-5. Plaintiffs alleged that between 2006 and 2010, Goldman maintained an artificially inflated stock price by making generic statements in SEC filings and annual reports about its conflict-of-interest policies, including statements that “We have extensive procedures and controls that are designed to identify and address conflicts of interest,” “Our clients’ interests always come first,” and “Integrity and honesty are at the heart of our business.” Plaintiffs alleged these statements were false or misleading because Goldman engaged in several conflicted transactions without disclosure. When the truth emerged through government enforcement actions and news reports, Goldman’s stock price allegedly dropped, causing losses to shareholders who purchased stock during the relevant period.
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