Defendants knew their statements were false when made or that they made misleading statements with deliberate recklessness. Additionally, Plaintiffs’ assertion that Defendants Tomkinson and Johnson received “spreadsheets and reports about the Company’s performance” on a weekly basis is insufficient to support an inference of scienter. Vague references to “packages” and “reports” are the type of boilerplate allegations that courts generally reject as evidence of scienter. See Silicon Graphics, 183 F.3d at 985 (if a complaint “purports to rely on the existence of internal reports, [it must] contain at least some specifics from those reports as well as such facts that may indicate their reliability”); In re Lockheed Martin Corp. Securities Litigation, 272 F.Supp.2d 944, 956 (C.D.Cal.2003) (<HOLDING>). 2. Solid Loan Acquisition Statements
holding insufficient the plaintiffs generic allegations holding allegations that defendant received regular updates regarding the status of the companys major projects were insufficient to allege scienter holding that plaintiffs conclusory allegations were insufficient to make out prima facie case for mere department status of foreign corporation defendant holding that allegations of motive and opportunity were not enough to create a strong inference of scienter holding that similar allegations were insufficient to state a due process claim