In Count I, Plaintiffs allege RHI committed insider trading in violation of the Exchange Act and Rule 10b-5 when Gilbert— RHI’s majority shareholder and Chairman—sold over 20 million shares of Rocket Class A common stock on March 29, 2021 armed with material, non-public information about Rocket’s financial forecast.6 Id. at PageID.8551–53.

11 Notably, as discussed in greater detail supra Section II.C.2, Coffman excluded March 2 and 3, 2021 from his event study as statistical “outliers” because these dates revealed a “spike in trading volume ... apparently fueled by investors on the Reddit forum site ‘r/wallstreetbets’ encouraging each other to buy Rocket Common Stock[.

As an additional example of context suggesting Farner’s statements had no impact on how the market viewed Case 1:21-cv-11528-TLL-APP ECF No. 226, PageID.40537 Filed 09/30/24 Page 32 of 66 Rocket’s profitability, Dr. Starks explains that analyst reports at the time frequently referenced the publicly available Freddie Mac and Fannie Mae forecasts that Rocket’s key performance metrics would—like other players in the mortgage industry—decline as interest rates rose.

In re Scrap Metal Antitrust Litig., 527 F.3d 517, 529 (6th Cir. 2008) (rejecting argument which “fundamentally confuse[d]” the accuracy of a proposed expert’s opinion with its reliability); United States v. Ramer, 883 F.3d 659, 680 (6th Cir. 2018) (noting that, so long as an expert’s testimony is based on sufficient facts and data and is free from speculation, “any remaining challenges merely go to ... weight, as opposed to ... admissibility”).

At bottom, Defendants have shown that Dr. Garmaise is qualified, based on his knowledge, experience, and education, to testify as an expert on how shifting market perceptions of Rocket stock throughout the Class Period render artificial inflation—a necessary variable in Plaintiffs’ proposed class-wide damages methodology—difficult to quantify.

None are persuasive.

... held that the defendants “managed to sever the link between back-end price drop and front-end misrepresentation” through the “introduction of Dr. Starks’s analysis of 880 analyst reports published during the Class Period . . . none ...

Defense Counsel: Now you’re saying, after lunch, it was actually a lot easier than that and none of that stuff actually happened, and all you sent your lawyer was one trade confirmation for you and your monthly account statement for your ...

SOUTHERN CALIFORNIA, individually and on behalf of all others similarly situated,

Case No. 1:21-cv-11528 Honorable Thomas L. Ludington United States District Judge

In August 2024, the Parties in this putative securities-fraud class action1 filed the following motions to seal: ECF No.

Further, it is ORDERED that the Parties are DIRECTED to file the full and unredacted versions of the various motions and exhibits, identified in their above-listed motions to seal, under seal.

United States District Judge

Non-Disclosure of Confidential Information – Any document or thing designated as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” may only be used to prosecute or defend this action and shall not be disclosed to (or the content discussed with) anyone other than the following persons:

The named parties in this case, their attorneys, and their support staff (e.g., copying and document management personnel).

Materials designated as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” shall not be disclosed by opposing counsel to a former employee of Plaintiff or Defendant, respectively, or to a testifying or non-testifying expert or consultant unless and until such representative, expert, or consultant has first been supplied with and has read a copy of this Order and has executed a copy of the Agreement attached as Exhibit A. Current employees of Plaintiff and Defendant are not required to execute a copy of the Confidentiality Agreement, but must be advised regarding the provisions of this Protective Order.

Objections – Should any party object to a designation of any information, documents, or things as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” the parties shall, on an expedited basis, meet and confer in a good-faith attempt to reach an agreement regarding the status of the Case 2:22-cv-10228-LJM-EAS ECF No. 49, PageID.952 Filed 07/24/24 Page 6 of 9 information, documents, or things.

Survival – The terms of this Order shall remain in effect after the action and any related appeals are concluded, except that there shall no longer be Case 2:22-cv-10228-LJM-EAS ECF No. 49, PageID.954 Filed 07/24/24 Page 8 of 9 any restriction on use of materials designated as “Confidential” that are used as exhibits at trial (unless such exhibits were used under seal or protective order at trial).