On February 28th, a U.S. District Court dismissed a lawsuit brought by public retirement funds against a private equity fund of funds. Plaintiffs allege that the private equity fund fraudulently inflated the value of one of the funds in its offering materials, violating Section 12(a)(2) of the Securities Act. Dismissing the complaint, the Court holds that because the securities at issue were sold in a private offering under Section 4(2) and Regulation D, plaintiffs failed to state a claim under Section 12(a)(2). Brockton Retirement Board v. Oppenheimer Global Resource Private Equity Fund I, L.P.