omitted). II. Heightened Pleading Standard Applicable to “Scienter” under the PSLRA Congress enacted the Private Securities Litigation Reform Act of 1995 (“PSLRA”) to discourage abusive securities litigation by private parties. Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308, 313, 127 S.Ct. 2499, 168 L.Ed.2d 179 (2007). “Exacting pleading requirements are among the control measures Congress included in the PSLRA.” Id. Specifically, with respect to the element of intent, the PSLRA provides that to survive a motion to dismiss, the complaint must “state with particularity facts giving rise to a strong inference that the defendant acted with the required state of mind.” 15 U.S.C. § 78u-4(b)(1)-(2); see also Tellabs, 551 U.S. at 313, 127 S.Ct. 2499 (internal citation, omitted) (<HOLDING>); In re Ceridian Corp. Securities Litigation,
holding that the plaintiff bears the burden to show that the defendant acted with intent to deceive holding that a plaintiff need not have notice of the defendants specific intention to deceive before the fraud action accrued all that is relevant is that a reasonable person  would have been on notice of a potential misrepresentation holding that the statute requires actual intent to hinder delay or defraud creditors or the trustee constructive intent to defraud does not suffice holding defendants possession of fake ids was sufficient to infer his intent to defraud or deceive holding that the pslra requires plaintiffs to state with particularity  the facts evidencing scienter ie the defendants intention to deceive manipulate or defraud