On July 26th, the U.S. District Court for Massachusetts dismissed securities fraud claims brought under the Securities Exchange Act, but allowed the claims brought under the Securities Act to move forward. The Exchange Act claims, the Court held, failed to adequately plead scienter. When it analyzed the Securities Act allegations, the Court found they do not sound in fraud. It noted that alleging "materially misleading" and "inaccurate" statements do not transform a negligence-based claim into a fraud-based claim. The Court concludes: "This case perfectly exemplifies the fact that statutes do matter. The PSLRA [Private Securities Litigation Reform Act]… was intended to protect corporate officers from groundless suits. Here it may possibly shield such officers from discovery of wrongdoing. The protection of corporate officers was not a legislative goal of the Securities Act, passed during the Great Depression. That part of the case may press forward. The result is an interesting end run around the discovery bar of the PSLRA." Lenartz v. American Superconductor Corp.