Complaints of fraudulent reviews insufficient to support securities fraud claims against Yelp. The FTC disclosed complaints that Yelp had manipulated reviews of certain businesses. Shareholders alleged that Yelp knowingly made false statements about the authenticity of its posted reviews and the FTC's disclosure caused their stock to lose value. Plaintiffs also alleged that Yelp insiders sold more than 1.1 million shares of their Yelp stock at artificially inflated prices. The US Court of Appeals for the Ninth Circuit held that plaintiffs failed to adequately plead loss causation and scienter. The disclosure of consumer complaints that refer to allegations of fraud, without more, is insufficient to allege loss causation. Allegations of suspicious insider stock sales without historical trading data did not create a strong inference of scienter. (11/21/2017) Curry v. Yelp, Inc.