statements about Sanofi’s maintenance of an “effective compliance organization” or Sanofi’s “efforts toward transparency, accountability, and disclosure” are too general to cause a reasonable investor to rely on them. See ECA, 553 F.3d at 205-06. Each of the statements is an example of corporate “puffery,” “which does not give rise to securities violations.” Id. at 206. In ECA Local, the Second Circuit held that JP Morgan Chase’s (“JPMC”) statements about risk management and corporate integrity — that JPMC had “risk management processes [that] are highly disciplined and designed to preserve the integrity of the risk management process,” and that JPMC “set the standard for integrity” — could not be the basis for a securities violation. Id. at 205-06. See also San Leandro, 75 F.3d at 811 (<HOLDING>); Lasker v. New York State Elec. & Gas Corp.,
holding that ejstoppel requires among other things reasonable reliance on the other partys actions and rejecting estoppel where plaintiffs could not reasonably have been misled holding that a defendants sentence was reasonable in part because it was well below the statutory maximum holding insureds general assertion that it expected a liability policy to cover such negligent acts as insured was alleged to have committed would not support application of reasonable expectations doctrine holding that the sentence was reasonable in part because it was well below the statutory maximum holding that general announcements by philip morris that it was optimistic about its earnings and expected marlboro to perform well were mere puffery and could not have misled a reasonable investor