On September 16th, the Eighth Circuit affirmed the dismissal of plaintiffs' securities fraud complaint. In doing so, the Court addressed what constitutes sufficient disclosure by manufacturers of potentially flawed medical devices. The Court held defendants' disclosure was adequate since it informed of the potential problem without unequivocally stating that the device was safe. Plaintiffs also failed to allege that the omitted statistical information concerning the device would have put investors on notice that either doctor error was not a significant factor in the device failures or that the overall failure rate of the device was statistically higher than that of other devices. Detroit General Retirement System v. Medtronic, Inc.