On February 16th, the U.S. District Court for the Northern District of Illinois entered summary judgment in favor of two individual securities fraud defendants. They cannot be liable under Section 20(a) of the Exchange Act because they lacked general control over the company's operations. Knowledge concerning the company is not control over the company. Plaintiffs failed to allege that a third individual defendant made material misstatements or omissions. However, that defendant's speaking on behalf of the company, involvement in earnings meetings, and approval of the release of intellectual property supports a genuine issue of fact that he exercised general control over operations, and the Section 20(a) claim against him survives. Silverman v. Motorola, Inc.