Case: 20-15638, 08/03/2021, ID: 12191174, DktEntry: 48, Page 1 of 16
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`No. 20-15638
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`IN THE UNITED STATES COURT OF APPEALS
`FOR THE NINTH CIRCUIT
`
`In re ALPHABET, INC. SECURITIES LITIGATION
`
`
`
`STATE OF RHODE ISLAND, Office of the Rhode Island Treasurer on behalf of
`the Employees’ Retirement System of Rhode Island; Lead Plaintiff, Individually
`and On Behalf of All Others Similarly Situated,
`Plaintiff-Appellant,
`v.
`ALPHABET, INC., LAWRENCE E. PAGE, SUNDAR PICHAI, RUTH M.
`PORAT, GOOGLE LLC, KEITH P. ENRIGHT and JOHN KENT WALKER, JR.,
`
`Defendants-Appellees.
`On Appeal from the United States District Court
`for the Northern District of California
`No. 4:18-cv-06245-JSW
`Honorable Jeffrey S. White
`
`OPPOSITION TO MOTION TO STAY
`
`ROBBINS GELLER RUDMAN & DOWD LLP
`JASON A. FORGE
`MICHAEL ALBERT
`J. MARCO JANOSKI GRAY
`TING H. LIU
`655 West Broadway, Suite 1900
`San Diego, CA 92101
`Telephone: 619/231-1058
`
`Lead Counsel for Plaintiff-Appellant
`
`
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`State of Rhode Island v. Alphabet, Inc., et al.,
`Ninth Circuit No. 20-15638
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`CORPORATE DISCLOSURE STATEMENT
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`Appellant and lead plaintiff State of Rhode Island, Office of the Rhode Island
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`Treasurer on behalf of the Employees’ Retirement System of Rhode Island is not a
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`corporate party, does not issue stock, and is not controlled by any publicly held
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`corporation.
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`I. 
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`II. 
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`TABLE OF CONTENTS
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`Page
`INTRODUCTION ........................................................................................... 1 
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`LEGAL STANDARD ..................................................................................... 2 
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`III.  BACKGROUND ............................................................................................. 2 
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`A.  Defendants Continue to Revise the Complaint’s Allegations ............... 2 
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`B. 
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`Defendants’ Revisionism Extends to This Court’s Opinion ................. 4 
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`IV.  ARGUMENT ................................................................................................... 5 
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`A.  Defendants’ Proposed Petition Does Not Concern Two of
`Plaintiff’s Three Claims ........................................................................ 5 
`
`B. 
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`Defendants’ Described Petition Will Raise No Legitimate
`Questions of Law ................................................................................... 6 
`
`C. 
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`There Is No Good Cause to Grant Defendants’ Requested Stay .......... 9 
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`V. 
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`CONCLUSION .............................................................................................. 10 
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`TABLE OF AUTHORITIES
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`Page
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`CASES
`Hollingsworth v. Perry,
`558 U.S. 183 (2010) ...................................................................................... 2, 4, 9
`United States v. Silver,
`954 F.3d 455 (2d Cir. 2020) ............................................................................... 10
`STATUTES, RULES AND REGULATIONS
`15 U.S.C.
`§78j(b) ........................................................................................................... 5, 6, 9
`Federal Rules of Appellate Procedure
`Rule 41 .................................................................................................................. 2
`Rule 41(d)(1) ......................................................................................................... 2
`Ninth Circuit Rules
`Rule 41-1 ........................................................................................................... 1, 2
`17 C.F.R.
`§240.10b-5(a) ...............................................................................................passim
`§240.10b-5(b).................................................................................................. 6, 10
`§240.10b-5(c) ...............................................................................................passim
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`I.
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`INTRODUCTION
`After failing to move to dismiss two of Plaintiff’s three principal liability
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`claims, twice failing to convince a single Judge on this panel, and failing to secure a
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`single request for a vote for en banc consideration, Defendants proclaim that,
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`“[p]lainly [it] is not the case” (Defs.’ Mot.1 at 1) that their planned petition for
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`certiorari “would be frivolous or filed merely for delay.” 9th Cir. R. 41-1.
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`Defendants’ hyperbole betrays exactly what they “[p]lainly” deny. A petition for
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`certiorari here would be both frivolous and just another delay tactic.
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`Defendants’ self-described petition does not reach Plaintiff’s claims under
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`Rules 10b-5(a) and (c). Regarding the lone claim it addresses, Defendants rely on
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`rank revisionism, of both the Consolidated Amended Complaint (the “Complaint”)
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`and this Court’s opinion, with the same telling hyperbole: “Under the panel’s new
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`rule, every public company whose ‘business model is based on trust’ (Op. 27) will be
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`subjected to an affirmative duty to disclose any and all problems it has experienced –
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`even if the problems no longer exist at the time of disclosure, and even if the relevant
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`public statements are neither false nor misleading.” Defs.’ Mot. at 5. Defendants’
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`description is not fair, as this Court faithfully followed binding precedent and created
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`no new rules. Plaintiff respectfully requests that this Court deny Defendants’ motion.
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`
`1
`“Defs.’ Mot.” refers to Defendants-Appellees’ Motion to Stay the Mandate
`Pending Filing of a Petition for a Writ of Certiorari (ECF No. 47).
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`II. LEGAL STANDARD
`Under Rule 41 of the Federal Rules of Appellate Procedure and this Court’s
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`Rule 41-1, a party seeking to stay the mandatory issuance of this Court’s mandate
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`pending the filing of a petition for a writ of certiorari “must show that the petition
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`would present a substantial question and that there is good cause for a stay.” Fed. R.
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`App. P. 41(d)(1) (emphasis added); 9th Cir. R. 41-1 (motions to stay mandate “will
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`not be granted as a matter of course, but will be denied if the Court determines that the
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`petition for certiorari would be frivolous or filed merely for delay”). As the Supreme
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`Court has held:
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`To obtain a stay pending the filing and disposition of a petition for
`a writ of certiorari, an applicant must show (1) a reasonable probability
`that four Justices will consider the issue sufficiently meritorious to grant
`certiorari; (2) a fair prospect that a majority of the Court will vote to
`reverse the judgment below; and (3) a likelihood that irreparable harm
`will result from the denial of a stay.
`Hollingsworth v. Perry, 558 U.S. 183, 190 (2010).
`
`III. BACKGROUND
`A. Defendants Continue to Revise the Complaint’s Allegations
`This Court does not need a refresher on the underlying facts. But Defendants’
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`recidivist revisionism demands another call out, particularly because they are now
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`revising this Court’s opinion. Once again, Defendants refuse to acknowledge or
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`challenge the Complaint’s actual allegations and instead try to limit Plaintiff’s case to
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`what the Complaint explicitly describes as “just the tip of the iceberg” (Excerpts of
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`Record (ECF No. 8) (“ER”) 45-46:¶73) and a mere “symptom of the disease
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`comprising” a much greater concealed problem. ER43:¶63.
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`Since Defendants had steadfastly refused to acknowledge the written word,
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`Plaintiff’s counsel hoped to break through with a verbal correction to begin the oral
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`argument before this Court:
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`We have never alleged nor argued that a single software bug that was
`completely eradicated, without anything more, would be enough to
`sustain this case. That is not the case we’ve alleged. That is not the case
`we want you to reinstate. Instead, we’ve alleged far more than that. We
`alleged a single software bug that took the defendants almost three years
`to discover, but that discovery led to the discovery of a much much
`bigger problem.
`2/4/2021 Oral Argument at 0:50-1:40.
`
`This Court had no difficulty realizing and acknowledging that the Complaint’s
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`allegations far transcend a single “fully-remediated software ‘Bug’” (Defs.’ Mot. at
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`3):
`
`Not only did Google’s security protocols fail to detect the problem
`for three years, but Google also had a limited set of activity logs that
`could review only the two most recent weeks of user data access. Due to
`this record-keeping limitation, Google “had no way of determining how
`many third-parties had misused its users’ personal private data.” And
`Google “could only estimate that it exposed to third-parties the personal
`private data of hundreds of thousands of users” based on “less than 2%
`of the Three-Year Bug’s lifespan.” Despite the efforts of “over 100 of
`Google’s best and brightest,” Google “could not confirm the damage
`from [the bug] or determine the number of other bugs.” At the same
`time, this investigation into the Three-Year Bug detected other
`shortcomings in Google’s security systems, including “previously
`unknown, or unappreciated, security vulnerabilities that made additional
`data exposures virtually inevitable.” The complaint refers collectively to
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`the Three-Year Bug and these additional vulnerabilities as the “Privacy
`Bug.”
`6/16/2021 Opinion (ECF No. 42-1) (“Op.”) at 9-10.
`
`These failings, limitations, and uncontainable additional vulnerabilities were so
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`significant that they had a dramatic (albeit undisclosed) impact on Google’s business:
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`“despite Google+ having 395 million monthly active users, more than either Twitter
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`or Snapchat, Pichai and Page approved a plan to shut down the Google+ consumer
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`platform.” Id. at 10. But, “[t]he complaint alleges that key officers and directors,
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`including Page and Pichai, chose a strategy of nondisclosure. Pichai approved a plan
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`to conceal the existence of the Three-Year Bug and other security vulnerabilities
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`described in the Privacy Bug Memo ‘to avoid any additional regulatory scrutiny,
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`including having to testify before Congress.’” Id.
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`Undeterred by both written and spoken words, Defendants’ motion returns to
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`the same discredited refrain: “Plaintiff’s complaint generally alleges that two Form
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`10-Qs filed by Alphabet were misleading because they failed to disclose a fully-
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`remediated software ‘Bug’ within the Google+ social network.” Defs.’ Mot. at 3.
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`B. Defendants’ Revisionism Extends to This Court’s Opinion
`Much like their description of the Complaint’s allegations, Defendants’
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`description of this Court’s opinion bears almost no resemblance to the real thing.
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`Once again, Defendants’ resort to hyperbole gives them away:
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`
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`
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`“[T]he panel’s decision manufactures a novel, free-standing duty that
`virtually all publicly traded companies must disclose all prior security
`vulnerabilities, even when they have been resolved and even when the
`company made no affirmative statements on the subject.” Defs.’ Mot. at
`5.
`
`“Under the panel’s new rule, every public company whose ‘business
`model is based on trust’ (Op. 27) will be subjected to an affirmative duty
`to disclose any and all problems it has experienced – even if the
`problems no longer exist at the time of disclosure, and even if the
`relevant public statements are neither false nor misleading.” Id.
`
`
`
`“Given the potential litigation risks attendant with non-disclosure under
`the panel’s rule, the likely result is public disclosure of every issue a
`business faces during the course of its ordinary operations, however
`quickly addressed and however fully resolved.” Id. at 6 (emphasis in
`original).
`As set forth below, this Court’s opinion created no new duties or rules. Just the
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`opposite, in fact, as the Court repeatedly acknowledged the existent precedent that
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`largely dictated its decision.
`
`IV. ARGUMENT
`A. Defendants’ Proposed Petition Does Not Concern Two of
`Plaintiff’s Three Claims
`This Court held that “the district court erred in sua sponte dismissing Rhode
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`Island’s claims under Rule 10b-5(a) and (c) when Alphabet had not targeted those
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`claims in its motion to dismiss, [and] reverse[d] dismissal of the claims under Section
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`10(b) and Rule 10b-5(a) and (c) and remand[ed] to the district court.” Op. at 38.
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`These “scheme” and “business practices” claims comprise two of Plaintiff’s three
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`principal liability claims, with the third being a claim under §10(b) and Rule 10b-5(c).
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`Defendants’ motion for stay does not question this Court’s reversal as to Plaintiff’s
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`claims under §10(b) and Rules 10b-5(a) and (c) (and it is too late to do so in their
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`reply brief). Because Defendants’ own motion concedes that its potential petition for
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`a writ of certiorari would not reach two of Plaintiff’s three principal liability claims,
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`delay is the only purpose of Defendants’ proposed petition as to them. For this reason
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`alone, Defendants’ motion should be denied.
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`B. Defendants’ Described Petition Will Raise No Legitimate
`Questions of Law
`Defendants reconstruct this Court’s opinion as defying precedent to allow any
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`lawyer with a pen and legal pad to bring pitiful trillion-dollar conglomerates like
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`Alphabet to their knees. Tellingly missing from Defendants’ narrative, however, is a
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`single word, phrase, or sentence in which this Court purported to announce any new
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`rule, duty, or standard. Not so much as an extension or variation. Instead, this Court
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`methodically cited and described the well-established rules of law it was bound to
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`follow and did follow. The following are just examples:
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`We apply the objective standard of a “reasonable investor” to
`determine whether a statement is misleading. See In re VeriFone Sec.
`Litig., 11 F.3d 865, 869 (9th Cir. 1993). Section 10(b) and Rule 10b-
`5(b) “do not create an affirmative duty to disclose any and all material
`information” and instead require disclosure “only when necessary ‘to
`make . . . statements made, in light of the circumstances under which
`they were made, not misleading.’” Matrixx Initiatives, Inc. v.
`Siracusano, 563 U.S. 27, 44 (2011) (quoting 17 C.F.R. §240.10b-5(b)).
`A misleading omission is material if “there is ‘a substantial
`likelihood that [it] would have been viewed by the reasonable investor as
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`having significantly altered the “total mix” of information made
`available’ for the purpose of decisionmaking by stockholders concerning
`their investments.” Retail Wholesale & Dep’t Store Union Loc. 338 Ret.
`Fund v. Hewlett-Packard Co., 845 F.3d 1268, 1274 (9th Cir. 2017)
`(quoting Basic Inc. v. Levinson, 485 U.S. 224, 231-32 (1988)). The
`inquiry into materiality is “fact-specific,” Matrixx Initiatives, 563 U.S. at
`43 (quoting Basic, 485 U.S. at 236), and “requires delicate assessments
`of the inferences a ‘reasonable shareholder’ would draw from a given set
`of facts and the significance of those inferences to him,” Fecht v. Price
`Co., 70 F.3d 1078, 1080 (9th Cir. 1995) (quoting TSC Indus., Inc. v.
`Northway, Inc., 426 U.S. 438, 450 (1976)). “[T]hese assessments are
`peculiarly ones for the trier of fact.” Id. (quoting TSC Indus., 426 U.S. at
`450). As a result, resolving materiality as a matter of law is generally
`appropriate “only if the adequacy of the disclosure or the materiality of
`the statement is so obvious that reasonable minds could not differ.” Id.
`at 1081 (cleaned up); see Khoja v. Orexigen Therapeutics, Inc., 899 F.3d
`988, 1014 (9th Cir. 2018) (same).
`Op. at 18-19; see also id. at 27 n.6 (“In light of our precedent, we decline to follow
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`the Sixth Circuit’s unpublished decision in Bondali v. Yum! Brands, Inc., which held
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`that a statement disclosing future harms generally would not mislead a reasonable
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`investor about the current state of a corporation’s operations.”) (emphasis added).
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`Defendants’ narrative also cannot be reconciled with the fact that this Court’s
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`adherence to precedent did not always inure to Plaintiff’s benefit. This Court upheld
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`the dismissal of several allegedly misleading statements after describing the relevant
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`existing legal standard:
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`We have held that “transparently aspirational” statements,
`Hewlett-Packard, 845 F.3d at 1278, as well as statements of “mere
`corporate puffery, vague statements of optimism like ‘good,’ ‘well-
`regarded,’ or other feel good monikers,” are generally not actionable as a
`matter of law, because “professional investors, and most amateur
`investors as well, know how to devalue the optimism of corporate
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`executives,” Police Ret. Sys. of St. Louis v. Intuitive Surgical, Inc., 759
`F.3d 1051, 1060 (9th Cir. 2014) (quoting In re Cutera Sec. Litig., 610
`F.3d 1103, 1111 (9th Cir. 2010)). Such statements rise to the level of
`materially misleading statements only if they provide “concrete
`description of the past and present” that affirmatively create a plausibly
`misleading impression of a “state of affairs that differed in a material
`way from the one that actually existed.” See In re Quality Sys., Inc. Sec.
`Litig. (Quality Systems), 865 F.3d 1130, 1144 (9th Cir. 2017) (cleaned
`up).
`Id. at 20, 37. While Plaintiff may not agree with this particular application of law, we
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`would not mischaracterize it as creating a “novel” or “new” duty or rule that will lead
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`to apocalyptic consequences.
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`At bottom, had this Court created a “new rule, [under which] every public
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`company whose ‘business model is based on trust’ (Op. 27) will be subjected to an
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`affirmative duty to disclose any and all problems it has experienced – even if the
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`problems no longer exist at the time of disclosure, and even if the relevant public
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`statements are neither false nor misleading” (Defs.’ Mot. at 5), as Defendants assert,
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`that might have presented an important question of law. But this Court did no such
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`thing, as proved by the opinion itself2 and corroborated by the fact that not one of this
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`Court’s nearly 30 active judges so much as requested a vote to rehear this case en
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`Defendants cherry pick the phrase “business model based on trust” from a
`2
`lengthy paragraph of the opinion that expressly presents Alphabet’s business model as
`just one of “several reasons” why this Court rejected Defendants’ argument that their
`omissions could not have been misleading. Op. at 27-28.
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`banc. Therefore, Defendants’ petition would not present any questions of law of any
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`importance, revealing it to be just a delay tactic.
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`C. There Is No Good Cause to Grant Defendants’ Requested
`Stay
`Defendants’ entire argument for good cause is that, “[i]f this litigation is not put
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`on hold pending Defendants’ petition for certiorari, the parties will begin to incur the
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`substantial costs associated with discovery, pretrial motions, and trial preparation in
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`this complex securities case.” Defs.’ Mot. at 15. This is specious for two reasons.
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`First, by definition, to not put a case on hold is to allow it to proceed and accrue
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`normal litigation expenses. Therefore, if postponing accrual of normal litigation
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`expenses constituted good cause, it would exist for every case, rendering this
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`requirement superfluous. Under Hollingsworth, good cause requires far more: “a
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`likelihood that irreparable harm will result from the denial of a stay.” 558 U.S. at 190.
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`The second reason Defendants’ argument is specious is that even they do not
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`contend that their petition reaches this Court’s decision regarding Plaintiff’s claims
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`under §10(b) and Rules 10b-5(a) and (c). These “scheme” and “business practices”
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`liability claims comprise two of Plaintiff’s three principal liability claims and
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`Defendants did not move to dismiss them. Defendants have no basis to attack this
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`Court’s reinstatement of these unchallenged claims, which explains why Defendants’
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`own description of their planned petition does not reach this aspect of this Court’s
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`opinion. This means that even if Defendants had a legitimate question of law
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`regarding this Court’s reinstatement of Plaintiff’s claim under Rule 10b-5(b) (and they
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`do not), and even if the Supreme Court resolved Plaintiff’s claim under Rule 10b-5(b)
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`in Defendants’ favor, all normal litigation expenses would still be incurred by virtue
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`of Plaintiff’s unchallenged claims under Rules 10b-5(a) and (c). Therefore,
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`Defendants’ motion to stay presents no potential preservation of resources, but rather
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`a temporary redirection, and delay in the expenditure, of resources. No court has ever
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`held that such circumstances constitute good cause to further delay the litigation of a
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`case that should not have been delayed in the first place.3
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`V. CONCLUSION
`For all the foregoing reasons, as well as those set forth in Plaintiff’s prior briefs,
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`letters, and at oral argument, Plaintiff respectfully requests that the Court deny
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`Defendants’ motion to stay the mandate pending their pursuit of a petition for a writ of
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`certiorari.
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`DATED: August 3, 2021
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`
`
`
`Respectfully submitted,
`
`s/ Jason A. Forge
`JASON A. FORGE
`
`
`See, e.g., United States v. Silver, 954 F.3d 455, 460 (2d Cir. 2020) (The
`3
`argument that failure to stay the mandate would send the defendant to prison on a
`conviction that might later be reversed “is true for virtually every criminal defendant
`seeking a writ of certiorari.” Also, the intended certiorari petition did not attack all
`counts of conviction – “making it all but certain that he would serve at least some time
`in prison even in the unlikely event that he were to succeed before the Supreme Court
`on the other counts of conviction.”).
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`ROBBINS GELLER RUDMAN
` & DOWD LLP
`JASON A. FORGE
`MICHAEL ALBERT
`J. MARCO JANOSKI GRAY
`TING H. LIU
`655 West Broadway, Suite 1900
`San Diego, CA 92101
`Telephone: 619/231-1058
`619/231-7423 (fax)
`Lead Counsel for Plaintiff-Appellant
`
`
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`UNITED STATES COURT OF APPEALS
`FOR THE NINTH CIRCUIT
`Form 15. Certificate of Service for Electronic Filing
`Instructions for this form: http://www.ca9.uscourts.gov/forms/form15instructions.pdf
`
`9th Cir. Case Number(s)
`
`I hereby certify that I electronically filed the foregoing/attached document(s) on
`this date with the Clerk of the Court for the United States Court of Appeals for the
`Ninth Circuit using the Appellate Electronic Filing system.
`
`Service on Case Participants Who Are Registered for Electronic Filing:
`I certify that I served the foregoing/attached document(s) via email to all
`registered case participants on this date because it is a sealed filing or is
`submitted as an original petition or other original proceeding and therefore
`cannot be served via the Appellate Electronic Filing system.
`
`Service on Case Participants Who Are NOT Registered for Electronic Filing:
`I certify that I served the foregoing/attached document(s) on this date by hand
`delivery, mail, third party commercial carrier for delivery within 3 calendar
`days, or, having obtained prior consent, by email to the following unregistered
`case participants (list each name and mailing/email address):
`
`Description of Document(s) (required for all documents):
`
`Date
`Signature
`(use “s/[typed name]” to sign electronically-filed documents)
`Feedback or questions about this form? Email us at forms@ca9.uscourts.gov
`
`Form 15
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`Rev. 12/01/2018
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`20-15638
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`Opposition to Motion to Stay
`
`s/Jason A. Forge
`
`08/03/2021
`
`