In re Iris Energy Limited Securities Litigation
1:24-cv-07046
| E.D.N.Y | Jan 7, 2025Background
- Paul Williams-Israel filed a securities class action against Iris Energy Limited (IREN), its co-CEOs, and CFO, alleging securities fraud under Sections 10(b), 20(a) of the Securities Exchange Act and Rule 10b-5, for a class period from June 20, 2023 to July 11, 2024.
- Multiple parties (Bunney, Li, Gregor, Maletta) moved for appointment as lead plaintiff and for court approval of their chosen lead counsel under the PSLRA; Gibbons filed but later withdrew.
- A proper PSLRA notice was published on BusinessWire, triggering a 60-day window for class members to move for appointment as lead plaintiff.
- The main criterion for lead plaintiff was the largest financial interest in the relief sought; Bunney had the greatest net losses ($123,639.66) from IREN trades during the class period.
- Other movants (Li, Gregor, Maletta) did not oppose Bunney’s motion upon realizing he had the largest financial interest.
- The decision also addressed court approval for Bunney’s selected co-lead counsel (Glancy Prongay & Murray LLP and Holzer & Holzer, LLC) based on their experience and qualifications.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper appointment of lead plaintiff under PSLRA | Bunney: has largest financial interest, satisfies Rule 23 | No opposition from other movants | Bunney appointed as lead plaintiff (largest loss, typicality, adequacy). |
| Adequacy/typicality of proposed lead plaintiff | Bunney: claims and losses arise from same events as class | Not contested | Bunney found to meet Rule 23 typicality and adequacy requirements. |
| Selection and approval of lead counsel | Bunney: selected experienced, qualified counsel | No opposition | Bunney's selection (GPM and Holzer) approved as co-lead counsel. |
| Rebuttal of PSLRA presumption by other movants | None; other movants do not contest Bunney’s status | N/A | No rebuttal; Bunney’s presumption as 'most adequate plaintiff' stands. |
Key Cases Cited
- In re Flag Telecom Holdings, Ltd. Sec. Litig., 574 F.3d 29 (2d Cir. 2009) (typicality and adequacy standards for lead plaintiffs)
- Robidoux v. Celani, 987 F.2d 931 (2d Cir. 1993) (requirements for typicality under Rule 23)
- Baffa v. Donaldson, Lufkin & Jenrette Sec. Corp., 222 F.3d 52 (2d Cir. 2000) (inquiry for adequacy under Rule 23)