from actual witnesses, albeit unnamed, that defendants knowingly violated GAAP procedures and present more than mere evidence of a motive and opportunity to commit fraud. Although plaintiffs’ allegations of Daou’s top-to-bottom management hierarchy, defendants’ suspicious stock sales, or the corporate acquisitions alone would not likely demon strate defendants’ scienter, these plus the complaint’s specific allegations of deliberate accounting misfeasance create a strong inference of scienter. See Nursing Home, 380 F.3d at 1234 (“Considered separately, Plaintiffs’ allegations may not create a strong inference of scienter. However, ... [w]e find that the totality of the allegations does create a strong inference that Oracle acted with scienter[.]”); cf. Silicon Graphics, 183 F.3d at 988 (<HOLDING>). Unlike in Silicon Graphics, this complaint
holding vague allegations of bias insufficient holding that similar allegations were insufficient to state a due process claim holding that eonclusory allegations that plaintiffs were unaware of the conspiracy is insufficient holding insufficient the plaintiffs generic allegations holding that the plaintiffs unsupported allegations about the defendants travels to the district were insufficient to create personal jurisdiction