New York Times

April 16, 2019

"Private plaintiffs likely will cite the decision in the Lorenzo case to claim that a misstatement or failure to disclose information operated as a scheme to defraud, which means that anyone involved in putting out misleading information could be sued. That could significantly expand the number of potential defendants who can be sued for securities fraud and carry the possibility for significant recoveries from those with deep pockets who played some role in sending out misleading information to investors."

https://www.nytimes.com/2019/04/16/business/dealbook/supreme-court-sec-fraud.html