(CAC ¶ 60). Because this statement is qualified by the phrase “[biased on my knowledge,” the falsity of the statement is entirely dependent on what Viehbacher knew, not on what was objectively true at the time of the statement. See City of Monroe, 2011 WL 4357368, at *14 (quoting Podany v. Robertson Stephens, Inc., 318 F.Supp.2d 146, 154 (S.D.N.Y.2004)) (internal quotation marks omitted) (“In cases alleging a false statement of opinion, the falsity and scienter requirements are essentially identical” because “a material misstatement of opinion is by its nature a false statement, not about the objective world, but about the defendant’s own belief’). Plaintiffs have failed to allege any facts showing that Viehbacher did not believe what he said. See City of Omaha, 679 F.3d at 67-68 (<HOLDING>). Moreover, as later explained, plaintiffs do
holding that the burden to allege facts sufficient to establish jurisdiction resides with plaintiff holding that the burden is on the plaintiff to allege facts sufficient to establish jurisdiction holding that the burden is on the plaintiff holding that plaintiff bears the burden to timely allege facts supporting equitable tolling holding that the burden is on the plaintiff to plausibly allege that the speaker did not truly hold that opinion