In recent years, courts have been increasingly called on to address whether public statements touting corporations’ compliance programs can provide the basis for securities fraud claims when the corporations end up committing, or allegedly committing, misconduct. The Southern District of New York faced this issue recently in In re Sanofi Sec. Litigation, No. 14-cv-9624 (S.D.N.Y. Jan. 6, 2016). In this putative class action, the plaintiffs alleged that the defendant pharmaceutical company had engaged in illegal kickbacks to customers, while at the same time touting its integrity and compliance efforts. The corporation allegedly issued a corporate social responsibility report that claimed it “maintain[ed] an effective compliance organization” focused on “establishing and enforcing clear rules that are consistent with the legislative framework and are aligned with the industry’s best practices, while seeking to go beyond regulatory compliance through our efforts toward transparency, accountability, and disclosure.” Further, its CEO allegedly made a statement during a conference call with analysts that the company “has very tight compliance programs” and said on another occasion that the company had “zero tolerance for any unethical conduct.” After finding that the substantive kickback allegations were not sufficiently pled, the court also found these compliance-related statements to be unactionable because they were “too general to cause a reasonable investor to rely on them” and were mere “corporate ‘puffery’” which does not give rise to securities violations. Accordingly, the court dismissed the complaint.