On September 7th, the Northern District of Ohio applied the Supreme Court's decision in Janus Capital Group, Inc. v. First Derivative Traders, 131 S. Ct. 2296 (2011), to partially dismiss a shareholder lawsuit. Shareholders of Dana Corp. sued its former executives alleging that they falsified the firm's financial information in violation of Rule 10b-5. In light of the Supreme Court's opinion in Janus, the District Court held that the proper inquiry for whether an individual defendant might be liable is whether that defendant had ultimate authority over the false statements in question. Hawaii Ironworkers Annuity Trust Fund v. Cole.