Securities & Investment Fraud

Mallinckrodt plc Securities Class Litigation

Securities and Financial Fraud

Introduction

Securities fraud class action litigation has been filed on behalf of investors in Mallinckrodt plc (“Mallinckrodt” or the “Company”) (NYSE: MNK). If you purchased or otherwise acquired the securities of Mallinckrodt between November 25, 2014 and January 18, 2017, inclusive (the “Class Period”), you may move the court for appointment as lead plaintiff by no later than March 27, 2017.

You may retain Lieff Cabraser Heimann & Bernstein, LLP, or other attorneys, as your counsel in the actions. Recognized by the National Law Journal as one of the nation’s top plaintiffs’ law firms, Lieff Cabraser is committed to safeguarding the rights of investors and upholding the integrity of the market. We have significant experience and a successful track record of representing institutional and individual investors in securities and financial fraud litigation.

Mallinckrodt investors may choose to have Lieff Cabraser review their claim by completing the contact form below. You can also call Sharon M. Lee of Lieff Cabraser at 1-800-541-7358 to discuss the litigation.

Background on the Mallinckrodt Securities Class Litigation

The action alleges that Mallinckrodt, an Irish pharmaceutical company, misrepresented and/or failed to disclose its dependence on Medicare and Medicaid reimbursements for revenues for its therapeutic andrenocorticotropic hormone (“ACTH” or “Acthar”) drugs used to treat infantile spasms and other conditions, and that it maintained a monopoly on Acthar treatments in the U.S., which threatened the sustainability of its reimbursement revenues.

On November 9, 2015, Citron Research (“Citron”) issued a statement on Twitter comparing Mallinckrodt to Valeant Pharmaceuticals, Inc., whose stock price had plummeted 30% after Citron accused Valeant of fraud. On this news, Mallinckrodt’s stock price fell 17%, to close at $58.01 per share.

On November 16, 2016, Citron published a report accusing Mallinckrodt and its Chief Executive Officer (“CEO”) of fraud in connection with the statements the CEO made downplaying the Company’s reliance on Medicare and Medicaid for Acthar revenue. The Citron report revealed that Medicare and Medicaid payments accounted for approximately 61% of the Company’s total Acthar revenue in 2015. On this news, the Company’s stock price fell 18.4%, to close at $55.32 per share.

On November 29, 2016, Mallinckrodt’s CEO disclosed on a conference call that Acthar represented “a significantly greater proportion of [the Company’s] operating income than one-third.” On this news, the Company’s stock price declined 9.1%, to close at $52.42 per share.

On January 18, 2017, the Federal Trade Commission and several states filed a lawsuit and simultaneously entered into a settlement with Mallinckrodt for $100 million for the Company’s anticompetitive conduct with respect to its Acthar pricing. On this news, the Company’s stock price fell 5.85% to close at $46.53 per share.


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II. TRANSACTIONS IN MALLINCKRODT SECURITIES

Number of shares of Mallinckrodt securities held immediately before the start of the Class Period on November 25, 2014:

From November 25, 2014 through January 18, 2017, inclusive, I made the following transactions in Mallinckrodt securities:

PURCHASES

Date
No. of Shares
Price

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SALES

Date
No. of Shares
Price

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During the 90 days after January 18, 2017, I made the following transactions in Mallinckrodt securities:

SALES

Date
No. of Shares
Price

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Comments & questions:

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About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, Nashville, and Seattle, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for fourteen years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News have named Lieff Cabraser as a “Law Firm of the Year” for each year the publications have given this award to law firms.

Universal Health Services Securities Class Litigation

Securities and Financial Fraud

Introduction

Securities fraud class action litigation has been filed on behalf of investors in Universal Health Services, Inc. (“UHS”) (NYSE: UHS). If you purchased or acquired the publicly traded securities of UHS between February 26, 2015 and December 7, 2016, inclusive (the “Class Period”), you may move the court for appointment as lead plaintiff by no later than February 21, 2017.

You may retain Lieff Cabraser Heimann & Bernstein, LLP, or other attorneys, as your counsel in the actions. Recognized by the National Law Journal as one of the nation’s top plaintiffs’ law firms, Lieff Cabraser is committed to safeguarding the rights of investors and upholding the integrity of the market. We have significant experience and a successful track record of representing institutional and individual investors in securities and financial fraud litigation.

UHS investors may choose to have Lieff Cabraser review their claim by completing the contact form below. You can also call Sharon M. Lee of Lieff Cabraser at 1-800-541-7358 to discuss the litigation.

Background on the UHS Securities Class Litigation

UHS is a Pennsylvania-based operator of behavioral healthcare facilities, inpatient acute care hospitals, and free-standing emergency departments.

The action alleges that UHS misrepresented and/or failed to disclose its improper and illicit practice of admitting and holding patients by exaggerating their symptoms and discharging patients only after their insurance payments ran out to maximize the Company’s profits.

On December 7, 2016, BuzzFeed News published an article detailing its year-long investigation of the Company which revealed that UHS had a widespread, top-down practice of making patient admission and discharge decisions based on anticipated profit, rather than patient care considerations. BuzzFeed News’s investigation was reportedly “based on interviews with 175 current and former UHS staff, including 18 executives who ran UHS hospitals; more than 120 additional interviews with patients, government investigators, and other experts, and a cache of internal documents.”

The article stated that “[c]urrent and former employees from at least 10 UHS hospitals in nine states said they were under pressure to fill beds by almost any method – which sometimes meant exaggerating people’s symptoms or twisting their words to make them seem suicidal – and to hold them until their insurance payments ran out.” On this news, UHS’s stock price plummeted $15.01 per share, or nearly 12%, from its previous closing price of $126.37 on December 6, 2016, to close at $111.36 per share on December 7, 2016.


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II. TRANSACTIONS IN UHS SECURITIES

Number of UHS shares held immediately before the start of the Class Period on February 26, 2015:

From February 26, 2015 through December 7, 2016, inclusive, I made the following transactions in UHS shares:

PURCHASES

Date
No. of Shares
Price

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SALES

Date
No. of Shares
Price

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During the 90 days after December 7, 2016, I made the following transactions in UHS shares:

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Price

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Comments & questions:

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About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, Nashville, and Seattle, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for fourteen years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News named Lieff Cabraser as a “Law Firm of the Year” for 2016, and Benchmark Litigation included our firm in its 2016 “Top 10 Plaintiffs Firms” listing.

Tenet Healthcare Corporation Securities Class Litigation

Securities and Financial Fraud

Introduction

Securities fraud class action litigation has been filed on behalf of investors in Tenet Healthcare Corporation (“Tenet”) (NYSE: THC). If you purchased or acquired the securities of Tenet between February 28, 2012 and October 3, 2016, inclusive (the “Class Period”), you may move the court for appointment as lead plaintiff by no later than December 6, 2016.

You may retain Lieff Cabraser Heimann & Bernstein, LLP, or other attorneys, as your counsel in the actions. Recognized by the National Law Journal as one of the nation’s top plaintiffs’ law firms, Lieff Cabraser is committed to safeguarding the rights of investors and upholding the integrity of the market. We have significant experience and a successful track record of representing institutional and individual investors in securities and financial fraud litigation.

Tenet investors may choose to have Lieff Cabraser review their claim by completing the contact form below. You can also call Sharon M. Lee of Lieff Cabraser at 1-800-541-7358 to discuss the litigation.

Background on the Tenet Securities Class Litigation

Tenet, headquartered in Dallas, Texas, primarily operates acute care hospitals and related healthcare facilities.

The action alleges that Tenet misrepresented and/or failed to disclose that it perpetrated an illegal conspiracy to defraud the United States and to make illegal kickback payments for patient referrals to certain Tenet hospitals between 2000 and 2013.

The conspiracy involved Hispanic Medical Management, d/b/a “Clinica de la Mama” (or “Clinica”), a Georgia corporation that operated clinics for pregnant Hispanic women, many of whom were undocumented. Clinica received over $12 million in kickbacks from some executives at Tenet hospitals for illegally referring its patients to the hospitals. The hospitals, in turn, improperly billed and received over $146 million in reimbursements from Medicaid and Medicare for services provided to the unlawfully referred patients.

On August 1, 2016, Tenet announced after the close of the market that it had reached an agreement in principle with the United States government to resolve the civil and criminal investigations of the conspiracy. The agreement provided that Tenet would pay a nearly $514 million settlement, enter into a non prosecution agreement (“NPA”), and that two Tenet subsidiaries would plead guilty to a single count indictment, among other terms. On this news, the price of Tenet’s common stock fell $1.34 per share, or 4.64%, from its previous closing price, to close at $27.57 per share on August 2, 2016.

On October 3, 2016, Tenet announced that the settlement was final and revealed details of the NPA. On this news, Tenet’s stock price fell $0.91 per share, or 4.02%, from its previous closing price, to close at $21.75 per share on October 3, 2016.


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II. TRANSACTIONS IN TENET SECURITIES

Number of Tenet shares held immediately before the start of the Class Period on February 28, 2012:

From February 28, 2012 through October 3, 2016, inclusive, I made the following transactions in Tenet shares:

PURCHASES

Date
No. of Shares
Price

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SALES

Date
No. of Shares
Price

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During the 90 days after October 3, 2016, I made the following transactions in Tenet shares:

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No. of Shares
Price

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Comments & questions:

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About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, Nashville, and Seattle, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for thirteen years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News have named Lieff Cabraser as a “Law Firm of the Year” for each year the publications have given this award to law firms.

American Renal Associates Holdings, Inc.

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Introduction

Securities fraud class action litigation has been filed on behalf of investors in American Renal Associates Holdings, Inc. (“ARA” or the “Company”) (NYSE: ARA). If you purchased or otherwise acquired the securities of American Renal Associates Holdings, Inc. (“ARA” or the “Company”) (NYSE: ARA) between April 20, 2016 and August 18, 2016, inclusive (the “Class Period”), and/or pursuant or traceable to American Renal’s false and misleading Registration Statement and Prospectus issued in connection with the Company’s initial public offering of common stock (“IPO”) on or about April 21, 2016, you may move the Court for appointment as lead plaintiff by no later than October 31, 2016.

You may retain Lieff Cabraser Heimann & Bernstein, LLP, or other attorneys, as your counsel in the actions. Recognized by the National Law Journal as one of the nation’s top plaintiffs’ law firms, Lieff Cabraser is committed to safeguarding the rights of investors and upholding the integrity of the market. We have significant experience and a successful track record of representing institutional and individual investors in securities and financial fraud litigation.

ARA investors may choose to have Lieff Cabraser review their claim by completing the contact form below. You can also call Sharon M. Lee of Lieff Cabraser at 1-800-541-7358 to discuss the litigation.

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II. TRANSACTIONS IN AMERICAN RENAL ASSOCIATES SECURITIES

Number of Securities - American Renal Associates shares held immediately before the start of the Class Period on February 28, 2012:

From February 28, 2012 through October 3, 2016, inclusive, I made the following transactions in American Renal Associates shares:

PURCHASES

Date
No. of Shares
Price

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SALES

Date
No. of Shares
Price

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During the 90 days after October 3, 2016, I made the following transactions in American Renal Associates shares:

SALES

Date
No. of Shares
Price

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Background on the ARA Securities Class Litigation

ARA is a Massachusetts-based provider of outpatient dialysis services, which owns 200 dialysis clinics throughout the country for patients suffering from chronic kidney failure or end stage renal disease.

The actions allege that ARA filed a false and misleading Prospectus as part of its April 22, 2016 IPO Registration Statement, and subsequently continued those misrepresentations, when it failed to disclose that ARA illegally steered patients who qualified for Medicare and Medicaid plans into more expensive Affordable Care Act (“ACA”) plans to obtain greater reimbursement for ACA’s services. ARA allegedly funded a third-party charitable organization (the American Kidney Fund, or “AKA”) to pay private insurance premiums only for treatments that would benefit ARA, and predominantly in locations without “in network” dialysis centers, so that ARA would be paid “out-of-network” rates.

Nonetheless, ARA’s Prospectus maintained that ARA “adhere[d] to stringent billing, reimbursement, and compliance procedures,” and ACA later stated that patients “opt[ed for” ACA products, despite illicitly steering patients to those same services.

On July 2, 2016, three affiliates of the insurer UnitedHealth Group (“United Health”) filed suit against ARA alleging that it had engaged in a “fraudulent and illegal scheme” that violated various state anti-kickback and insurance fraud statutes, in which ARA convinced patients eligible for Medicare and Medicaid to enroll in UnitedHealth plans by referring them to AKA, which paid their insurance premiums. On this news, the price of ARA’s stock price fell $2.82 per share, or 9.88%, from a previous closing price of $28.53, to close at $25.71 on the next trading day, July 5, 2016, on elevated trading volume.

On July 27, 2016, Anthem, Inc. reported that it was reviewing the reasons behind “higher than expected payments for dialysis payments during the first half of the year.”

On August 18, 2016, the Centers for Medicare and Medicaid Services (“CMS”) announced that it had launched an investigation into whether dialysis centers such as ARA were steering eligible Medicare and Medicaid recipients to “individual market plan[s]” to obtain[] higher rates.” On this news, the price of ARA’s shares fell $2.31 per share, or 10.44%, from a previous closing price of $22.21, to close at $19.81 on August 19, 2016, on extremely heavy trading volume.

About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, Nashville, and Seattle, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for thirteen years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News have named Lieff Cabraser as a “Law Firm of the Year” for each year the publications have given this award to law firms.

BofI Holding, Inc. Securities Class Litigation

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Lieff Cabraser serves as Lead Counsel for a proposed class of shareholders in BofI Holding, Inc. (“BofI”) in a securities fraud lawsuit against BofI and certain of BofI’s senior executives and directors. BofI is a San Diego, California-based holding company of BofI Federal Bank, a federal savings bank that provides online banking services and products under brands such as “Bank of Internet” and “NetBank.”

The class action, in which the Houston Municipal Employees Pension System has been appointed Lead Plaintiff, alleges that throughout the Class Period of September 4, 2013 through February 3, 2016, defendants touted BofI’s purportedly conservative loan-underwriting standards and compliance with legal and regulatory obligations while, in fact, secretly manipulating BofI’s financials, engineering lucrative related-party transactions between BofI and senior officials, and flouting banking and consumer protection laws and other laws. The action alleges additional wrongdoing at BofI, including maintaining undisclosed lending partnerships pursuant to which BofI originated high-risk loans and reaped millions of dollars in origination fees and the ability to report growth in loan originations and improved efficiency without accounting for the attendant risks.

When investors learned that Defendants were allowing BofI to engage in far riskier practices than Defendants represented, the price of BofI common stock, which traded as high as $142.54 per share during the Class Period, fell significantly, to $63.98 per share (pre-split adjusted) by the end of the Class Period, thereby causing Lead Plaintiff and other Class Members to suffer damages.

On October 13, 2015, The New York Times reported that a former internal auditor at BofI filed an action against BofI alleging widespread misconduct at the Company, including by BofI’s Chief Executive Officer, defendant Gregory Garrabrants, who allegedly abused his powerful position at the Company for personal gain. Numerous other former BofI employees have also provided accounts of serious wrongdoing at BofI.

The case is Houston Municipal Employees Pension System v. BofI Holding, Inc., et al., No. 3:15-cv-02324 (S.D. Cal.). A copy of the consolidated amended complaint is available here.

If you would like more information about the litigation, or have information relevant to the lawsuit, please use the form below or contact Richard Texier of Lieff Cabraser toll-free at 1-800-541-7358 or at rtexier@lchb.com.

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We produce a free e-mail Civil Justice Newsletter three to four times a year, and distribute it to persons who have contacted us and wish to receive the newsletter.

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About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, Nashville, and Seattle, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for fourteen years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News named Lieff Cabraser as a “Law Firm of the Year” for 2016, and Benchmark Litigation included our firm in its 2016 “Top 10 Plaintiffs Firms” listing.

Petrobras Securities Litigation

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Janus Overseas Fund, et al. v. Petróleo Brasileiro S.A. – Petrobras, et al., No. 1:15-cv-10086-JSR (S.D.N.Y.); Dodge & Cox Global Stock Fund, et al. v. Petróleo Brasileiro S.A. – Petrobras, et al., No. 1:15-cv-10111-JSR (S.D.N.Y.).

Lieff Cabraser represented several funds managed by Janus and several funds managed by Dodge & Cox in individual securities cases arising from the massive fraud at Petrobras, a state-run semi-public energy and oil-production company headquartered in Rio de Janeiro, Brazil. Plaintiffs sought recovery under the federal securities laws for damages they suffered on transactions in Petrobras securities during the period December 29, 2010 through July 28, 2015 (the “Relevant Period”), due to a pervasive and long-running scheme of bribery and corruption at Petrobras.

Plaintiffs alleged that beginning around 2005 and continuing through the Relevant Period, the Company engaged in a scheme whereby contractors paid bribes to Petrobras executives and others in exchange for the award of lucrative oil and gas construction contracts. Some of the bribes were passed on to Brazilian politicians and political parties. The Company then paid the contractors inflated amounts under the contracts in order to repay them for the bribes. When the fraud was finally revealed beginning in May 2014, it sent shockwaves through the Brazilian government and economy, and caused Petrobras’s market capitalization to plummet. Authorities estimate the scheme has diverted up to, or more than, $28 billion from the Company’s coffers.

Lieff Cabraser’s cases were part of consolidated proceedings before Judge Jed S. Rakoff in the Southern District of New York. The parties reached settlements in the cases in October of 2016.

Amaya, Inc. Securities Class Litigation

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Introduction

Securities fraud class action litigation has been filed in federal court in New York on behalf of investors in Amaya, Inc. (“Amaya” or the “Company”) (Nasdaq: AYA). If you purchased Amaya securities between June 8, 2015 and March 23, 2016, inclusive (the “Class Period”), you may move the court for appointment as lead plaintiff by no later than May 24, 2016.

You may retain Lieff Cabraser Heimann & Bernstein, LLP, or other attorneys, as your counsel in the actions. Recognized by the National Law Journal as one of the nation’s top plaintiffs’ law firms, Lieff Cabraser is committed to safeguarding the rights of investors and upholding the integrity of the market. We have significant experience and a successful track record of representing institutional and individual investors in securities and financial fraud litigation.

Amaya investors may choose to have Lieff Cabraser review their claim by completing the contact form below. You can also call Sharon M. Lee of Lieff Cabraser at 1-800-541-7358 to discuss the litigation.

Background on the Amaya Securities Class Litigation

Amaya, headquartered in Quebec, Canada, is a provider of technology-based products and services in the global gaming and interactive entertainment industries.

The action alleges that defendants made false and/or misleading statements and/or failed to disclose: (1) that the Company’s Chief Executive Officer (“CEO”) during the Class Period, David Baazov, was engaged in an insider trading scheme that involved influencing the market price of the Company’s securities and communicating privileged information to third parties; (2) the Company lacked adequate internal controls; and, (3) that, as a result of the foregoing, defendants’ statements about Amaya’s business, operations, and prospects, were false and misleading and/or lacked a reasonable basis.

On March 23, 2016, news outlets reported that Baazov was charged with insider trading by Quebec securities regulators. Bloomberg reported that the charges included allegations of aiding with trades while in possession of privileged information, influencing or attempting to influence the market price of securities of Amaya, and communicating privileged information. On this news, Amaya’s stock fell $3.07 per share, or 21.54% from a closing price of $14.25 on March 22, 2016, to close at $11.18 per share on March 23, 2016, on extraordinarily heavy trading volume.

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II. TRANSACTIONS IN AMAYA SECURITIES

Number of Amaya shares held immediately before the start of the Class Period on February 28, 2012:

From February 28, 2012 through October 3, 2016, inclusive, I made the following transactions in Amaya shares:

PURCHASES

Date
No. of Shares
Price

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SALES

Date
No. of Shares
Price

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During the 90 days after October 3, 2016, I made the following transactions in Amaya shares:

SALES

Date
No. of Shares
Price

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Comments & questions:

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About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, Nashville, and Seattle, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for thirteen years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News have named Lieff Cabraser as a “Law Firm of the Year” for each year the publications have given this award to law firms.

Horizon Pharma PLC Securities Class Litigation

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Introduction

Securities fraud class action litigation has been filed on behalf of investors in Horizon Pharma PLC (“Horizon” or the “Company”) (Nasdaq: HZNP). If you purchased or otherwise acquired Horizon securities between March 13, 2014 and February 26, 2016, inclusive (the “Class Period”), you may move the court for appointment as lead plaintiff by no later than May 9, 2016.

You may retain Lieff Cabraser Heimann & Bernstein, LLP, or other attorneys, as your counsel in the actions. Recognized by the National Law Journal as one of the nation’s top plaintiffs’ law firms, Lieff Cabraser is committed to safeguarding the rights of investors and upholding the integrity of the market. We have significant experience and a successful track record of representing institutional and individual investors in securities and financial fraud litigation.

Horizon investors may choose to have Lieff Cabraser review their claim by completing the contact form below. You can also call Sharon M. Lee of Lieff Cabraser at 1-800-541-7358 to discuss the litigation.

Background on the Horizon Securities Class Litigation

Horizon is a biopharmaceutical company focused on orphan drug development. Its current business model involves acquiring other drug companies, and then marketing and selling the acquired products using specialty pharmacies called pharmacy benefit managers (“PMBs”), with which it has special relationships. As part of its business model, Horizon drastically increased the price of the drugs it obtained and, as a result, lost its Medicare, Medicaid, and cash business, which it offset through its Prescriptions-Made-Easy (“PME”) plan. Under that plan, doctors can send their patients’ prescriptions through a PMB partnered with Horizon that directly mails the prescription to the patient the next day. If the patient’s insurance rejects the prescription, Horizon would absorb the cost.

The action alleges that the use of PMBs and the Company’s PME plan was not a sustainable business practice and left Horizon vulnerable to regulatory scrutiny.

On September 23, 2015, Express Scripts Holding Co. – the second largest U.S. PMB – publically described Horizon’s price increases as “profiteering.” On this news, Horizon’s stock price dropped $1.90 per share, or 7.4% from a closing price of $25.69 on September 23, 2015, to close at $23.79 per share on September 24, 2015.

On October 19, 2015, The New York Times published an article criticizing Horizon’s business model and PME Program. On this news, the Company’s stock price fell $3.81 per share, or 19.98% from a closing price of $19.07 on October 19, 2015, to close at $15.26 per share on October 20, 2015.

On October 22, 2015, biopharmaceutical Depomed, Inc. issued a statement describing its rejection of an exchange offer from Horizon and detailing: (1) why Horizon’s price increases were not sustainable; (2) how many of Horizon’s drugs had been removed from the largest PMBs; and (3) how the PME Program damaged Horizon’s realized net sales as a percentage of gross sales. On this news, Horizon’s stock price dropped $1.71 per share, or 11.53% from a closing price of $14.83 on October 21, 2015, to close at $13.12 per share on October 22, 2015, on extremely high trading volume.

Finally, on February 29, 2016, Horizon disclosed that it had received a subpoena from the U.S. Attorney’s Office for the Southern District of New York regarding the Company’s use of financial assistance to help patients pay for the Company’s drugs, as well as its sales and marketing activities and relationship with pharmacies. On this news, Horizon’s stock price declined $2.63 per share, or 13.29% from a closing price of $19.79 on February 26, 2016, to close at $17.16 per share on February 29, 2016, on extraordinarily high trading volume.

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II. TRANSACTIONS IN HORIZON PHARMA SECURITIES

Number of Securities - Horizon Pharma shares held immediately before the start of the Class Period on February 28, 2012:

From February 28, 2012 through October 3, 2016, inclusive, I made the following transactions in Horizon Pharma shares:

PURCHASES

Date
No. of Shares
Price

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SALES

Date
No. of Shares
Price

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During the 90 days after October 3, 2016, I made the following transactions in Horizon Pharma shares:

SALES

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Price

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Comments & questions:

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About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, Nashville, and Seattle, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for thirteen years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News have named Lieff Cabraser as a “Law Firm of the Year” for each year the publications have given this award to law firms.

Flotek Industries, Inc. Securities Class Litigation

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Introduction

Securities fraud class action litigation has been filed on behalf of investors in Flotek Industries, Inc. (“Flotek” or the “Company”) (NYSE: FTK). If you purchased or otherwise acquired the securities of Flotek between October 23, 2014 and November 19, 2015, inclusive (the “Class Period”), you may move the court for appointment as lead plaintiff by no later than January 11, 2016.

You may retain Lieff Cabraser Heimann & Bernstein, LLP, or other attorneys, as your counsel in the actions. Recognized by the National Law Journal as one of the nation’s top plaintiffs’ law firms, Lieff Cabraser is committed to safeguarding the rights of investors and upholding the integrity of the market. We have significant experience and a successful track record of representing institutional and individual investors in securities and financial fraud litigation.

Flotek investors may choose to have Lieff Cabraser review their claim by completing the contact form below. You can also call Sharon M. Lee of Lieff Cabraser at 1-800-541-7358 to discuss the litigation.

Background on the Flotek Class Litigation

Flotek is a global diversified, technology-driven company that develops and supplies oilfield products, services and equipment to the oil, gas and mining industries, and other products that are sold in consumer and industrial markets.

The actions allege that, throughout the Class Period, defendants issued materially false and misleading statements to investors and/or failed to disclose that: (1) Flotek’s proprietary software application FracMax had data and process errors; (2) the reported production data from FracMax for three of the wells in the Company’s New York City Investor Presentation on September 11, 2015 were inaccurate; and (3) an application from the Company claiming to be FracMax available in the Apple iTunes Store does not work.

On November 9, 2015, the firm Bronte Capital published a report on Flotek asserting, among other things, that: (1) the production data of four proximate wells in Texas set forth in Flotek’s September 11, 2015 presentation to investors did not match the data of the Texas Railroad Commission; and (2) a version of FracMax available in the Apple iTunes Store does not work. On this news, the price of Flotek shares fell $3.50 per share, or 19.34%, from its closing price on November 6, 2015 to close at $14.60 per share on the next trading day, November 9, 2015, on extremely heavy trading volume.

On November 10, 2015, the Company issued a press release acknowledging data and process errors in its FracMax database and the understatement of production data in Company’s presentation on September 11, 2015. On this news, the price of Flotek shares fell $5.56 per share, or 38.1%, from its closing price on November 9, 2015, to close at $9.04 per share on November 10, 2015, on extremely heavy trading volume.

About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, and Nashville, and Seattle, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for thirteen years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News have named Lieff Cabraser as a “Law Firm of the Year” for each year the publications have given this award to law firms.

GNC Holdings Securities Class Litigation

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Introduction

Securities fraud class action litigation has been filed on behalf of investors in GNC Holdings, Inc. (“GNC” or the “Company”) (NYSE: GNC). If you purchased or otherwise acquired the securities of GNC between May 2, 2013 and October 22, 2015, inclusive (the “Class Period”), you may move the court for appointment as lead plaintiff by no later than December 28, 2015.

You may retain Lieff Cabraser Heimann & Bernstein, LLP, or other attorneys, as your counsel in the action. Recognized by the National Law Journal as one of the nation’s top plaintiffs’ law firms, Lieff Cabraser is committed to safeguarding the rights of investors and upholding the integrity of the market. We have significant experience and a successful track record of representing institutional and individual investors in securities and financial fraud litigation.

GNC investors may choose to have Lieff Cabraser review their claim by completing the contact form below. You can also call Sharon M. Lee of Lieff Cabraser at 1-800-541-7358 to discuss the litigation.

Background on the GNC Class Litigation

The action charges GNC and certain of its senior executives with violations of Sections 10(b) and 20(a) of the Securities Exchange Act of 1934, and Rule 10b-5 promulgated thereunder. GNC operates as a specialty retailer of health and wellness products.

The action alleges that, throughout the Class Period, defendants issued materially false and misleading statements and/or failed to disclose that: (1) GNC unlawfully sold thousands of units of products in Oregon containing picamilon and BMPEA; (2) GNC unlawfully sold thousands of units of products in Oregon that contained BMPEA; and (3) as a result of the foregoing, the Company’s public statements were materially false and misleading at all relevant times.

On October 22, 2015, the Oregon Attorney General announced a lawsuit against GNC arising from the Company’s sale of nutritional and dietary supplements containing the illegal ingredients picamilon and BMPEA. On this news, the price of GNC shares fell $5.73 per share, or 14.24% from a previous closing price of $40.23 on October 21, 2015, to close at $34.50 per share on October 22, 2015, on extremely heavy trading volume.

Shareholder Contact Form

We will review your claim without fee or obligation. Lieff Cabraser agrees to protect your name and all confidential information you submit against disclosure, publication or unauthorized use to the full extent under the law.

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II. TRANSACTIONS IN GNC HOLDINGS SECURITIES

Number of Securities - GNC Holdings shares held immediately before the start of the Class Period on February 28, 2012:

From February 28, 2012 through October 3, 2016, inclusive, I made the following transactions in GNC Holdings shares:

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During the 90 days after October 3, 2016, I made the following transactions in GNC Holdings shares:

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About Lieff Cabraser

Lieff Cabraser Heimann & Bernstein, LLP, with offices in San Francisco, New York, and Nashville, is a nationally recognized law firm committed to advancing the rights of investors and promoting corporate responsibility.

The National Law Journal has recognized Lieff Cabraser as one of the nation’s top plaintiffs’ law firms for twelve years. In compiling the list, the National Law Journal examines recent verdicts and settlements and looked for firms “representing the best qualities of the plaintiffs’ bar and that demonstrated unusual dedication and creativity.” Best Lawyers and U.S. News have also named Lieff Cabraser as a “Law Firm of the Year” each year the publications have given this award to law firms.