On June 10, 2020, the Ninth Circuit affirmed the dismissal of a putative securities fraud class action in a potentially significant decision for securities defendants, particularly those in the pharmaceutical, biotech and medical device space. The Ninth Circuit in Nguyen v. Endologix, Inc., No. 18-56322, 2020 WL 3069776 (9th Cir. June 10, 2020), held that