(emphasis added). Prior to the passage of the Securities Reform Act, the Second Circuit had the strongest pleading requirements for scien-ter amongst the circuits. Following the Act’s passage, the Second Circuit has repeatedly interpreted the Act’s heightened pleading requirements as echoing the standards previously adopted by the Second Circuit for pleading scienter in securities fraud cases. See Kalnit v. Eichler, 264 F.3d 131, 137 (2d Cir.2001); see also Novak v. Kasaks, 216 F.3d 300, 310 (2d Cir.) (interpreting the Reform Act as effectively raising the pleading standard to that previously existing in the Second Circuit and no higher), cert. denied, 531 U.S. 1012, 121 S.Ct. 567, 148 L.Ed.2d 486 (2000); Press v. Chemical Investment Services Corp., 166 F.3d 529, 537-38 (2d Cir.1999) (<HOLDING>). Accordingly, in the Second Circuit,
holding that heightened pleading standards do not apply to defamation actions holding that the federal false claims act is an antifraud statute to which rule 9bs heightened pleading requirements apply holding that the fact that federal rule of civil procedure 9b requires a heightened pleading standard for some claims but not for a section 1983 claim against a municipality means that the rules do not require a heightened pleading standard for such a claim 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 that the reform act heightened the re quirement for pleading scienter to the level used by the second circuit