The Second Circuit and Eleventh Circuit Courts of Appeal affirmed dismissal of securities fraud claims because the plaintiffs did not adequately plead scienter under the standard imposed by the Private Securities Litigation Reform Act of 1995. Scienter is defined as which of the following? (a) The standard of reasonableness required of a prudent person in the management of his affairs (b) An untrue statement of a material fact (c) The intent to deceive, manipulate, or defraud (d) The failure to maintain due diligence during the issuance of new securities known as an IPO
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