controls to ensure that they are accounted for in accordance with GAAP. SAC ¶ 126 (citing SEC Staff Accounting Bulletin No. 101: Revenue Recognition in Financial Statements, 17 C.F.R. Part 211, at 4 (Dec. 3, 1999)). Indeed, among its concessions regarding material misstatements and weaknesses in internal controls, Orthofix’s Restatement noted “extra-contractual terms or arrangements at the onset of sale,” and that such terms “were not evaluated, or not evaluated correctly” in the company’s files. SAC ¶¶ 110, 113. The plaintiff has alleged sufficient facts that raise a strong inference that Vaters and McCollum were aware of the revenue recognition problems that gave rise to the Restatement. See Varghese v. China Shenghuo Pharm. Holdings, Inc., 672 F.Supp.2d 596, 608 (S.D.N.Y.2009) (<HOLDING>). 3. The plaintiff alleges that it has raised a
holding that scienter requirement was met where gaap violations led to restatement and individual defendants were aware of weak internal controls holding that failure to follow gaap without more is insufficient to establish scienter holding that significant gaap violations described with particularity may provide powerful indirect evidence of scienter holding that 20 of individual defendants holdings raised an inference of scienter holding that a failure to maintain sufficient internal controls to avoid fraud is  indicative of scienter