The U.S. Court of Appeals for the Second Circuit raised the bar last week for when investors can sue companies for securities fraud over statements about clinical studies for products, securities litigation attorneys said.

A three-judge panel on Dec. 26 upheld the dismissal of a securities fraud lawsuit against Philip Morris International over the tobacco company’s statements characterizing its studies of the health benefits of one of its e-cigarettes as “rigorous” and “the best science.”

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