he Private Securities Litigation Reform Act of 1995 requires a plaintiff filing a securities fraud class action complaint pursuant to section 10(b) of the Securities Exchange Act of 1934 (the Exchange Act) to “state with particularity facts giving rise to a strong inference that the defendant acted with the required state of mind.” 15 U.S.C. § 78u-4(b)(2). The United States Supreme Court has explained that the “required state of mind” is “scienter, a mental state embracing intent to deceive, manipulate, or defraud.” Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308, 319 (2007).
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