On January 19th, the Eleventh Circuit affirmed the dismissal of a plaintiffs' lawsuit alleging that defendants committed a litany of securities violations. In doing so, the Court held that plaintiffs failed to allege that any individual defendant knew of alleged accounting irregularities, and failed to allege a link between defendants' allegedly false proxy solicitation and the plaintiffs' loss. The Eleventh Circuit also addressed the securities laws' safe harbor provisions for forward-looking statements holding that allegations of actual knowledge of falsity will not deprive a defendant of protection by the statutory safe harbor if his forward-looking statements are accompanied by meaningful cautionary language. Edward J. Goodman Life Income Trust v. Jabil Circuit, Inc.