On March 1st, the U.S. District Court for the Southern District of New York dismissed a lawsuit which alleged that defendants committed securities fraud by intervening in the auction rate securities (ARS) market to give the appearance of a stable market, and encouraged investors to purchase ARS. The Court held that extensive public information and disclosures including a SEC Order, trade confirmations, and prospectuses, revealed defendants' intervention. Plaintiffs therefore did not adequately plead deception or reliance. In re Citigroup, Inc., Auction Rate Securities Marketing Litigation.