On August 1st, the Northern District Court for Texas dismissed a shareholder securities fraud lawsuit for failing to adequately plead scienter. The plaintiffs' amended complaint relied on the SEC's complaint against the issuer's executive who allegedly knew or should have known of the accounting improprieties. However, the Court noted, the SEC only accused that executive of aiding and abetting books and records violations; it did not allege fraud and its requisite scienter. Rains v. Zale Corp.