point of disagreement among the courts turns on the “motive and opportunity” prong of the Second Circuit’s test, a standard which, standing alone, has been viewed' as less rigorous than that of intentional misconduct or recklessness. A number of courts have adopted the view that Congress intended the PSLRA to enhance pleading requirements in securities cases, and thus that allegations of motive and opportunity with nothing more would not create an inference of scienter sufficiently strong to satisfy the enhanced pleading stringency the PSLRA mandated to state a claim under § 10(b). See Silicon Graphics, 183 F.3d at 979 (adopting a pleading standard requiring facts demonstrating “deliberate or conscious recklessness”); Bryant v. Avado Brands, Inc., 187 F.3d 1271, 1282-86 (11th Cir.1999) (<HOLDING>); Comshare, 183 F.3d at 550 (equating
holding plaintiffs fraud claim failed rule 9b particularity requirement which in turn meant deceptive trade practices claim failed the particularity requirement holding that the group pleading doctrine did not survive the pslra because it cannot be reconciled with the pslras requirement that plaintiff state facts with particularity as to each alleged act or omission by the defendant holding that severe recklessness satisfies scienter requirement citation omitted holding that particular facts giving rise to a strong inference of deliberate recklessness at a minimum is required to satisfy the heightened pleading standard under the pslra holding that the pslra particularity requirement compels plaintiffs to allege severe recklessness