Alleged misuse of industry specific terms stated securities fraud claim. Investors in an oil and gas company claimed the defendants made material misstatements concerning the company’s prospects. Reinstating a dismissed complaint, the US Court of Appeals for the Fifth Circuit found that defendants’ use of the term “reserves” implied that certain testing had been successful when no testing had occurred. The complaint therefore adequately pleaded circumstances constituting at least severe recklessness and plaintiffs met the requirement to plead scienter. (7/15/2014) Spitzberg v. Houston American Energy Corp.