On March 14th, the Fourth Circuit held that the trial court properly denied securities fraud plaintiffs' motion to file a Third Amended Complaint ("TAC"). The partial disclosures concerning defendant's leveraged buyout identified in the TAC did not inform the market of defendant's alleged ongoing fraudulent omission. Even assuming the disclosures revealed that defendant knew the LBO would fail, the fact of such knowledge alone would still not suffice. To sufficiently plead loss causation, the TAC must have alleged facts showing that the disclosures revealed to the market something about the fraudulent nature of the press releases on which plaintiffs purportedly relied to their detriment because only then could the press releases have caused plaintiffs' economic loss. Katyle v. Penn National Gaming, Inc.