has two parts. First, he contends that the district court erred by approving the settlement because the Private Securities Litigation Reform Act (“PSLRA”) of 1995 does not allow it. Hayes correctly points out that Congress enacted the PSLRA to discourage frivolous securities class actions. Recognizing the “concern over the use of then-existing class action procedures to bring strike suits in order to exact extortionate settlements,” Congress enacted the PSLRA “to discourage frivolous lawsuits by establishing special procedures for instituting private class actions under the securities laws.” Hazen, Law of Securities Regulation § 12.15[1] (6th ed.2009) (quotation omitted). See also Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308, 322, 127 S.Ct. 2499, 168 L.Ed.2d 179 (2007) (<HOLDING>). However, Hayes mistakenly equates frivolous
holding that forum selection clause contained in contracts between lloyds and its investors applied to investors securities fraud claims against the syndicates that competed for investments within lloyds in light of the broad language of the clause and the syndicates pecuniary interest in uniform resolution of the claims recognizing that a limit on the governments ability to enter a consent decree would make it substantially more difficult to settle title vii litigation recognizing a commonlaw action to recover on a personal judgment recognizing the pslras twin goals to curb frivolous lawyerdriven litigation while preserving investors ability to recover on meritorious claims recognizing correspondence appeared to establish a settlement relationship between the parties given the letters presented an attempt to curb further litigation