In three opinions issued in 2018, the U.S. Court of Appeals for the Third Circuit clarified several pleading requirements for putative class action securities complaints.

One of the most consequential opinions of the past year issued by the Third Circuit was In re Hertz Global Holdings, 905 F.3d 106 (3d Cir., 2018). In that case, plaintiffs filed a securities fraud complaint against Hertz Global Holdings, Inc. and some of its current and former executives. The plaintiffs alleged that Hertz and these executives violated Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 and Rule 10b-5 by making materially false and misleading statements concerning the company’s financial results, internal controls and future earnings projections.