Law360, New York (April 9, 2015, 10:24 AM EDT) -- In opinions issued on the same day, federal appellate courts for the Second Circuit and the Eleventh Circuit both recently affirmed dismissals of securities fraud claims filed against independent audit firms that audited Chinese reverse-merger companies[1] because the plaintiffs did not adequately plead scienter under the heightened pleading standard imposed by the Private Securities Litigation Reform Act of 1995.[2] Under the PSLRA, plaintiffs must "state with particularity facts giving rise to a strong inference that the defendant acted with the required state of mind" with respect to each act or omission of the defendant that is alleged to violate the securities laws....