On November 1st, the U.S. District Court for the Eastern District of Virginia denied defendants’ motion to dismiss plaintiff’s state and federal securities fraud lawsuit. Plaintiff alleges defendants committed securities fraud by making material misstatements to induce him to invest over $32 million in defendants’ privately held company. The Court notes that the pleading of loss causation where the securities are privately held is different than when the securities are publicly traded. It concludes that here, plaintiff sufficiently alleged that defendants’ repeated misrepresentations induced plaintiff’s continued investment and that plaintiff’s reliance on those misrepresentations was the proximate cause of his injury. Carlucci v. Han.