upon ‘counsel’s investigation.’ ” (plf. memo in opp. at 9). Thus, they conclude, plaintiffs are not subject to the heightened pleading standard established by § 78u — 4(b)(1)(B). Several courts have held that when pleadings are based on counsel’s investigation of SEC filings, securities analyst’s reports, and information obtained from former employees, they are not pleading “based on information and belief’ and are therefore not subject to final provision of § 78u-4(b)(1)(B). See Zeid v. Kimberley, 973 F.Supp. 910, 915 (N.D.Cal.1997); Warman v. Overland Data, Inc., 1998 WL 110018, *3 (S.D.Cal.). Other courts have held that a general statement regarding “investigation of counsel” is insufficient to avoid PSLRA requirements. See, e.g., Novak v. Kasaks, 997 F.Supp. 425, 431 (S.D.N.Y.1998) (<HOLDING>). These holdings are not necessarily
holding that single paragraph asserting that plaintiffs based their information and belief on investigation of sec filings analysts reports press releases and discussions with consultants neither provided required facts underlying complaints allegations nor directed court to where facts could be found holding that plaintiffs need only allege that defendants provided information to the securities analysts upon which the reports were based holding that underlying complaints filed by several plaintiffs all contained express allegations of property damage and that because all complaints arose from the same set of circumstances the allegations in any single complaint can be inferred in the other complaints holding that plaintiffs may plead on information and belief if matters are not within their personal knowledge holding that scienter had not adequately been pled where the plaintiffs provided none of the required facts underlying the complaints allegations as to the information that was supposedly available to the individual defendants