against the other defendants. See Am.Compl. ¶ 23. 2 . The individual defendants also maintain that plaintiffs have engaged in impermissible group pleading. The court agrees. In view, however, of the continuing split among the district courts concerning whether the group pleading doctrine survived enactment of the Private Securities Litigation Reform Act of 1995 ("PSLRA"), 15 U.S.C. § 78u-4, compare, e.g., In re CIENA Corp Sec. Litig., 99 F.Supp.2d 650, 663 n. 11 (D.Md.2000) (stating in dicta that application of group pleading doctrine to non-speaking defendants "would seem to be inconsistent with the strict pleading requirements of the PSLRA” (citing Coates I, 26 F.Supp.2d at 916)) with, e.g., In re American Bank Note Holographics, Inc. Sec. Litig., 93 F.Supp.2d 424, 442 (S.D.N.Y.2000) (<HOLDING>), the absence of a controlling Fifth Circuit
holding that nothing in the pslra has altered that doctrine holding pslra abolished grouppleading doctrine holding that defendant has the burden of proving that a product has been altered unless the product has been lost whereupon plaintiff must bear the burden of persuasion if the defense of substantial change is raised holding that jurisdiction must be resolved before applying the act of state doctrine because that doctrine is a substantive rule of law recognizing doctrine