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In 2011, plaintiffs launched a putative class action with class members from California, New York, New Jersey, and Wisconsin in a New Jersey district court against Tropicana Products, Inc...

In a decision issued yesterday, the Second Circuit held that an accountant has a duty to correct its certified opinions, and may incur primary liability under § 10(b) and Rule 10b-5 if it fails to fulfill that duty in certain circumstances. The decision, written by C.J. Straub, claims to be the first in this Circuit to squarely hold that an accountant has such a duty or may be primarily liable under federal securities laws.