On July 29th, the Eighth Circuit affirmed, in part, a jury's accounting fraud verdict in the SEC's enforcement action against former infoUSA CFO Stormy Dean. Among other things, the Court held the SEC did not need to establish Dean's scienter in its claim that Dean solicited proxies by means of false or misleading proxy statements. Similarly, the SEC's claims for falsifying internal records did not require a showing of scienter. However, because the SEC did not allege defendant acted in bad faith against infoUSA's shareholders, that finding is vacated. SEC v. Dean.