On January 21st, the Tenth Circuit affirmed the dismissal of a securities fraud action against an issuer's auditor. Plaintiffs claim that the auditor knew or was reckless in not knowing that the issuer's revenue recognition policy violated GAAP, yet issued unqualified opinions nevertheless. The Court held that although the auditor's interpretation of GAAP may have been incorrect or negligent, the complaint does not establish an extreme departure from the standards of ordinary care or that no reasonable accountant would have made the same decision. Dronsejko v. Grant Thornton.