H.R. Conf. Rep. No. 104-369, 104th Cong., 1st Sess. 31 (1995) (Nov. 28, 1995) (“Conf. Rep.”). The Second Circuit’s basic standard was similar to that used in every other circuit as a plaintiff had to “plead that ‘in connection with the purchase or sale of securities, the defendant, acting with scienter, made a false material representation or omitted to disclose material information and that plaintiffs reliance on defendant’s action caused [plaintiff] injury.’ ” In re Time Warner Inc. Securities Litigation, 9 F.3d 259, 264 (2d Cir.1993) (quoting Bloor v. Carro, Spanbock, Londin, Rodman & Fass, 754 F.2d 57, 61 (2d Cir.1985)) (em 29, 538 (2d Cir.1999), Greebel v. FTP Software, Inc., 194 F.3d 185 (1st Cir.1999), and Williams v. WMX Techs., Inc., 112 F.3d 175, 177-78 (5th Cir.1997) (<HOLDING>). Unfortunately, the Eighth Circuit has not
holding that congress intended to adopt a standard more stringent than the prepslra second circuit standard holding that the pslra imposes a more rigorous pleading standard than applied by any of the courts of appeals prior to the enactment of the statute holding the pslra standard for pleading scienter is more stringent than the second circuits standard prior to the act and that motive and opportunity is not an independent basis to show defendants had scienter holding the pslra codified the prior standard set up by the second circuit holding reves standard narrower than existing second circuit precedent