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Concordia Healthcare Corp. T.CXR.R



TSX:CXR.R - Post by User

Comment by POMMERANTZon Mar 09, 2017 9:28am
75 Views
Post# 25956246

RE:RE:For Those Out of CXR or Short

RE:RE:For Those Out of CXR or ShortThe Class Action has been awarded to Rosen Law, BaggieCase 1:16-cv-06467-RMB Document 48 Filed 01/17/17 Page 1 of 4

INVESTOR COUNSEL

January 13, 2017

Jacob A. Goldberg jgoldberg@rosenlegal.com

Honorable Richard M. Berman
United States District Judge
United States District Court for the Southern District of New York 500 Pearl Street
New York, NY 10007-1312

Re: Meyer v. Concordia International Corp., et al, No. 16-cv-06467 Your Honor:

We write in response to the January 6, 2017 pre-motion letter (“letter”) of Defendants Concordia International Corp. (“Concordia”), Thompson, de Saldhana, Borkowski, and Kreppner (collectively, “Defendants”). Defendants fraudulently omitted material information relating to the sales efforts for their most important drug, Donnatal, in violation of the federal securities laws. Their motion to dismiss will fail.

As an initial matter, the Amended Class Action Complaint (“Complaint”) does not allege that Defendants issued any knowingly false revenue projections. This is not a “forward-looking statement” case, based on a knowingly false revenue projection. The cases Defendants cite in that regard are irrelevant. A portion of the alleged corrective disclosure on August 12, 2016 involved Concordia’s announcement that it was revising its revenue projection going forward, ¶¶87, 89, 91, and this announcement, and the announcement of disappointing sales of Concordia’s most important drug, Donnatal, led to the artificial inflation falling out of the stock price, but the Complaint does not allege the falsity of any revenue forecast.

Rather, the Complaint alleges, with particularity, Defendants’ repeated material omissions and false and misleading statements of then current and historical facts. By the start of the Class Period, May 13, 2016, encumbered by debt that had grown by over 1,400% in little more than a year, ¶¶5, 35, Concordia had serious problems. Many of the largest health insurers, with whom Defendants were in contact, had already dropped or were planning to drop from their formularies Donnatal, the Company’s largest and most important drug, ¶¶7, 36-37, 40-49, 70-73, whose cost per prescription Concordia had raised by 122%, to $782, in just two years. ¶¶39, 78, 82. Though Concordia issued risk disclosures warning of the theoretical risk that insurers might drop Donnatal from their formularies, Defendants chose not to reveal to investors that the risk had materialized. This material omission is actionable. See, e.g., Flynn v. Sientra, Inc., CV 15-07548 SJO (RAOx), 2016 WL 3360676, at *11-12 (C.D. Cal. June 9, 2016) (motion to dismiss denied, finding risk disclosure warning of non-compliance with regulatory rules false where regulator had already found violations, despite fact that losses due to regulatory shortcomings had yet to transpire); In re BioScrip, Inc., Sec. Litig., 95 F. Supp.3d 711, 736 (S.D.N.Y. 2015) (Defendants’ cautionary

THE ROSEN LAW FIRM, P.A. 101 GREENWOOD AVE., SUITE 440 JENKINTOWN, PA 19046TEL: (215) 600- 2817 FAX: (212) 202 - 3827

Case 1:16-cv-06467-RMB Document 48 Filed 01/17/17 Page 2 of 4

statements misleading because they “bespoke caution concerning an event already certain to occur, namely the severe downturn in revenue in the second quarter”).

Compounding the formulary issue was poor Donnatal sales. In January, 2016, the Company had contracted with an outside firm to enhance its Donnatal sales efforts, boosting its Donnatal sales staff by 75-80 salespersons, comprising at least 43% of the total Donnatal sales force. ¶¶50, 52, 56.1 On May 13, 2016, the same day Defendants touted Concordia’s Donnatal sales efforts in a first quarter, 2016, earnings conference call, Defendants fired all 75-80 outside sales persons. ¶¶9, 53, 65.

Concurrently, several companies were considering a buyout of Concordia, and Defendants chose not only to conceal the firings, but to answer direct questions as if the Donnatal salesforce remained intact. During the May 13, 2016 earnings conference call, when asked by analysts about Concordia’s Donnatal sales force, Defendants, who fired the entire contract sales force that same day, took turns pretending that they had not done so. Defendant Borkowski spoke of “our 175 person [Donnatal] sales teamas if it still existed, stating that Concordia’s promotional efforts would “ramp up during the next two quarters.” ¶¶56, 75. When asked directly whether Concordia was “committed to the promotion” of Donnatal for “at least another quarter or two,” Borkowski stated that “there is no reason at this point to do anything different,ignoring that having fired 75- 80 salespeople, they had already “do[ne] something different.” ¶¶58, 79. Defendant de Saldhana specifically stated, falsely, that the Company was “focused on [its] sales force efforts around Donnatal” and “you will see it more as the year builds.¶81. Defendant Thompson, Concordia’s CEO, asked how the Company would “better leverage [its] sales team,” and spoke of new opportunities for the sales force, ignoring the mass firing of that same day.2 ¶83. Finally, Defendant Kreppner, asked specifically about the Donnatal sales force and Concordia’s marketing strategy, spoke of the drug being “available,” ¶77, ignoring that it had been dropped from formularies, and declined to mention that Defendants had fired almost half the sales force that day.

Defendants cherry pick facts and draw illogical and, at this stage of the litigation, irrelevant inferences therefrom. For example, directly quoting Borkowski’s statement regarding the Company’s commitment to the promotion of Donnatal that “there is no reason at this point to do anything different,” Defendants draw the inference that since “the question did not ask about the size of the sales team,” the statement could not be false. This upends logic and the relevant case law. Having fired 75-80 Donnatal-dedicated sales persons, omitting mention of that material, existing fact when asked about the sales team was materially false. In In re Forest Laboratories Sec. Litig., No. 05 Civ. 2827 (RMB), 2006 WL 5616712, at *8 (July 21, 2006), this Court held that despite some true statements about its sales force’s communications with doctors, “[c]oncealment of the fact that Forest’s sales force (allegedly) improperly promoted Celexa for off-label uses may be misleading.” The Court quoted the Second Circuit’s opinion in Halperin v.

1 The impact on sales efforts was significantly greater even than the 43% number would indicate. The fired contract sales force sold only Donnatal, ¶50, while the remaining 95-100 salespersons sold an entire “bag” of different Concordia products. ¶83.

2 Defendants’ implication that Defendants’ statements should be judged differently “in the context of a live-action Q&A,” letter 2, is puzzling. Defendants cite to no case supporting the argument that this Court should apply a different standard to statements made by Company executives during a quarterly earnings conference call, especially since those executives surely understood that the opinions of the analysts on the call could affect the stock price.

THE ROSEN LAW FIRM, P.A. 101 GREENWOOD AVE., SUITE 440 JENKINTOWN, PA 19046TEL: (215) 600- 2817 FAX: (212) 202 - 3827

Case 1:16-cv-06467-RMB Document 48 Filed 01/17/17 Page 3 of 4

eBanker USA.com, Inc., 295 F.3d 352, 357 (2d Cir. 2002), which held that “the inquiry is not whether isolated statements within a document are true, but whether defendants’ representations or omissions, considered together and in context, would... mislead a reasonable investor regarding the nature of the securities offered.” Forest, 2006 WL 5616712, at *7.

Defendants ignore that, at the pleading stage, the court must accept as true all reasonable inferences in Plaintiff’s favor. See In re Ambac Fin. Grp., Inc. Sec. Litig., 693 F. Supp. 2d 241, 261 (S.D.N.Y. 2010). In assessing the Complaint’s well-pleaded allegations of falsity, this Court may not accept Defendantsalternative, unreasonable inferences. See In re Initial Public Offering Sec. Litig., 241 F. Supp.2d 281, 370 (S.D.N.Y. 2003) (“The role of the Court on a motion to dismiss is not to weigh evidence but merely to determine whether a claim has been pled.”).

Defendants wrongly posit that the Complaint must allege that the Defendants knew, on May 13, 2016, that failing to mention the firings would affect the stock price. Plaintiffs have adequately alleged a material misrepresentation or omission, scienter, and loss causation.3 The firing of half of the sales force for your most important drug is material, failing to mention this fact when directly asked about the sales force (or even if you were not asked) is an actionable omission, the defendants knew the firings were occurring the day they spoke with the analysts yet omitted any mention of the firings, establishing, at a minimum, recklessness, and thus scienter, and revelation of the disappointing Donnatal sales at the end of the Class Period, which can reasonably be tied to the firing of that same sales force and the drug being removed from many formularies, led to a 38% drop in the stock price, ¶¶12, 94, establishing loss causation.

In addition, the Complaint adequately pleads Defendants’ scienter. Plaintiffs may adequately allege scienter either through strong circumstantial evidence of recklessness or conscious misbehavior, or through evidence of motive. Ganino v. Citizens Utilities Co., 228 F.3d 154, 168- 69 (2d Cir. 2000). While the Complaint strongly pleads recklessness regarding the failure to disclose the firing of the Donnatal salesforce and the drug’s removal from formularies, Plaintiffs further adequately allege motive. Defendants were motivated to keep the stock price high and present a positive picture of cash flow as other companies considered a buyout, and Defendant Thompson was motivated to keep the stock price high because his shares were encumbered by a personal loan and subject to a margin call. ¶¶8, 104-106, 109-110. See, e.g., In re Worldcom, Inc. Sec. Litig., 294 F. Supp.2d 392, 416-17 (S.D.N.Y. 2003) (finding motive and scienter from the pressure of a margin call); see also Goldstein v. MCI Worldcom, 340 F.3d 238, 250 (5th Cir. 2003) (same).4

3 While a “formulaic recitation of the elements of a cause of action” does not suffice, the complaint “does not need detailed factual allegations” to survive a motion to dismiss. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007).

4 Defendants citation to In re Dynegy, Inc. Sec. Litig., 339 F. Supp.2d 804, 899 (S.D. Tex. 2004) for the general proposition that threat of a margin call is insufficient motive is directly contrary to the binding Fifth Circuit precedent in Goldstein which holds the opposite, 340 F.3d at 250, and to Worldcom, precedent in this Court that they ignore. 294 F. Supp.2d at 416 (while “motives possessed by virtually all corporate insiderssuch as protecting the appearance of corporate profits or increasing executive compensation by maintaining a high stock price are insufficient to plead scienter, Novak, 216 F.3d at 307,” Judge Cote wrote, a complaint sufficiently pleads motive and scienter where to avoid or mitigate margin calls from lenders, Ebbers faced substantial pressure to maintain the price of the WorldCom stock that was serving as his collateral”).

THE ROSEN LAW FIRM, P.A. 101 GREENWOOD AVE., SUITE 440 JENKINTOWN, PA 19046TEL: (215) 600- 2817 FAX: (212) 202 - 3827

Case 1:16-cv-06467-RMB Document 48 Filed 01/17/17 Page 4 of 4

This Court will deny Defendants’ motion to dismiss. Plaintiffs appreciate the opportunity to participate in the pre-motion conference on January 18, 2017.

cc: All counsel of record (via ECF)

Respectfully submitted,

/s/ Jacob A. Goldberg Jacob A. Goldberg, Esq.

THE ROSEN LAW FIRM, P.A. ♦ 


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