CrowdStrike Securities Litigation Analysis

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I found the core sources in `SEC Counsel/`, `General Counsel/`, and `Delta Litigation Case File/Ancillary Case_ Plymouth County Retirement v. CrowdStrike...`. I also found exactly one direct `Larry Stone` reference, in the stock transactions workbook.

- `SEC Counsel/Plymouth County Retirement Association CrowdStrike Class-Action Complaint.pdf` — the original Plymouth-filed securities complaint. Key pages: p.2 says “[This is a federal securities class action ... seeking to pursue remedies under Sections 10(b) and 20(a) ... and SEC Rule 10b-5](file:///root/workspace/SEC Counsel/Plymouth County Retirement Association CrowdStrike Class-Action Complaint.pdf:page_2)”; pp.24–25 plead the 10(b)/10b-5 and 20(a) counts and request Rule 23 class treatment; p.27 is Plymouth’s lead-plaintiff certification.

- `Delta Litigation Case File/Ancillary Case_ Plymouth County Retirement v. CrowdStrike.   Consolidated to In Re Crowdstrike/In Re CrowdStrike Holdings Consolidated Class Action.pdf` — the later consolidated amended class action. Key pages: p.4 names Thomas P. DiNapoli / NYSCRF as lead plaintiff and sets the class period; pp.92 and 96 cover the 10(b)/Rule 10b-5 and 20(a) claims; p.201 requests Rule 23 class certification.

- `SEC Counsel/Crowdstrike Shareholder Lawsuit_1.pdf` — NYSCRF’s lead-plaintiff motion. Key pages: pp.4–10 explain PSLRA “most adequate plaintiff,” largest financial interest, and Rule 23 typicality/adequacy; p.8 notes the 60-day lead-plaintiff deadline and that Plymouth filed the action on July 30, 2024.

- `General Counsel/CrowdStrike GC Memo (v1).docx` — board-level internal memo. p.1 says “Filed July 30, 2024; class certification pending;” and summarizes the securities class-action posture.

- `Delta Litigation Case File/Legal Memos/LEGAL BRIEF_ Shareholder Litigation Risk Analysis — CrowdStrike July 2024 Outage.docx` — prior risk memo. p.2 says “At least two putative class actions ... allege securities fraud under Exchange Act § 10(b) and Rule 10b-5”; pp.2–3 analyze MSA defenses and shareholder/derivative exposure.

- `Delta Litigation Case File/Legal Memos/CrowdStrike Litigation Summary and Update Memo.pdf` — current summary memo. p.3 says derivative actions are pending, CrowdStrike moved to consolidate/dismiss, and “No class certification has been sought” in those derivative matters.

- `Delta Litigation Case File/Legal Memos/Analysis of Litigation Exposure.docx` — broader exposure memo. p.1 frames the July 19 outage; p.8 calls the Plymouth-originating consolidated securities class action the “primary litigation in the securities context.”

- `Stock Transactions.xlsx` — only direct `Larry Stone` hit. `Sheet1` row 10 shows `Larry Stone | Purchase | 4/3/2024 | 56 | A | $168.40 | $9,430.40` (`11:11:/root/workspace/Stock Transactions.xlsx_parsed/page_1.md`).

Optional procedural background if you want the rule text itself:
- `SEC Counsel/federal-rules-of-civil-procedure.pdf` pp.63–66 for Rule 23 certification, notice, and exclusion/opt-out mechanics.
- `SEC Counsel/Securities Exchange Act.pdf` pp.317–319 for PSLRA lead-plaintiff appointment and the 90-day motion window.

If you want, I can turn this into a tighter “memo source map” organized by **complaint / internal memo / procedural authority / Larry Stone evidence**.

lines.offset/lines.limit are for plaintext/text-like files only. For PDF/Office docs use pages=[...] in text/visual mode.

lines.offset/lines.limit are for plaintext/text-like files only. For PDF/Office docs use pages=[...] in text/visual mode.

[lines 1-200 of SKILL.md]
1|---
2|name: docx
3|description: Read, create, edit, and review Microsoft Word files (.doc, .docx); handle tracked changes, comments, and OOXML workflows. For legacy .doc, read this skill first (section "Converting .doc to .docx"). Includes scripts for common docx automation.
4|---
5|
6|# DOCX Editing and Review
7|
8|## Overview
9|
10|Use `python-docx` for standard edits. Use OOXML workflows for tracked changes, comments, or direct XML manipulations.
11|
12|As with all skills, use absolute paths for script invocations.
13|
14|**Author attribution:** Comments and tracked changes use an author name (default: Raycaster). For collaborative workflows, pass the current user's name when available via `--author` or `author=` so attribution is correct. The agent may not have access to the user's name; otherwise the default is used.
15|
16|## Quick Reference
17|
18|| Task | Primary Path |
19||------|--------------|
20|| Convert `.doc` to `.docx` | `python /root/skills/docx/ooxml/scripts/soffice.py --headless --convert-to docx ...` |
21|| Add review comments | `python /root/skills/docx/scripts/add_comments.py ...` |
22|| Extract text quickly | `pandoc --track-changes=all ...` |
23|| Simple create/edit | `python-docx` |
24|| Tracked changes / redlines | Unpack -> OOXML edit -> pack (`ooxml.md`) |
25|| Accept/reject changes | `accept_all.py`, `reject_all.py`, or `review.py` |
26|| Validate OOXML output | `python /root/skills/docx/ooxml/scripts/validate.py ...` |
27|| Final visual QA | view tool (`path`, `mode="visual"`, `pages`); use `render_docx.py` only when you need output on disk or view fails |
28|
29|## Critical Rules
30|
31|- Convert legacy `.doc` files before any edits.
32|- Prefer `/root/skills/docx/ooxml/scripts/soffice.py` over raw `soffice` calls.
33|- If you must call `soffice` directly, include `-env:UserInstallation=file:///tmp/lo_profile_$$` to avoid profile lock/timeouts.
34|- Preserve existing template formatting when editing existing files.
35|- For tracked changes/comments, use OOXML workflows instead of plain `python-docx` edits.
36|- Programmatic text extraction (`pandoc`, `python-docx`) can miss embedded charts/images (DrawingML). When visuals matter, use the view tool with the document path and `mode="visual"` (and `pages` for long docs). Use `render_docx.py` only when you need rendered PDF/images written to a specific directory or when view fails.
37|- Keep author attribution explicit in comments and tracked revisions.
38|- Most scripts edit DOCX files in place.
39|- Never leave AI citation tokens in output (`[...†...]` or `【turn...】`).
40|- If you include citations inside Word comments, use human-readable references (page/section/paragraph/quote) or plain URLs. Do not paste internal citation tokens.
41|- Use ASCII hyphens unless the source document already requires specific Unicode characters.
42|
43|## Core Workflows
44|
45|### Converting .doc to .docx
46|
47|Legacy `.doc` files must be converted before editing:
48|
49|```bash
50|python /root/skills/docx/ooxml/scripts/soffice.py --headless --convert-to docx /root/workspace/document.doc
51|```
52|
53|The converted file is written in the same directory (e.g. `document.docx`).
54|
55|### Add Comments
56|
57|Use `/root/skills/docx/scripts/add_comments.py` with a JSON payload:
58|
59|```bash
60|python /root/skills/docx/scripts/add_comments.py /root/workspace/file.docx /root/tmp/comments.json --author "Reviewer"
61|```
62|
63|Options: `--author "Name"` (default: Raycaster)
64|
65|`comments.json` example:
66|
67|```json
68|[
69|  {
70|    "id": "CMT-001",
71|    "paragraph": 5,
72|    "text": "Comment on this paragraph.",
73|    "severity": "Major"
74|  },
75|  {
76|    "id": "CMT-001-R1",
77|    "parent_id": "CMT-001",
78|    "text": "Reply to the earlier comment thread.",
79|    "severity": "Info"
80|  },
81|  {
82|    "page": 3,
83|    "section": "Section 2.1",
84|    "text": "Clarify this section.",
85|    "severity": "Minor"
86|  },
87|  {
88|    "quote": "encryption at rest",
89|    "text": "Please clarify the encryption standards used.",
90|    "severity": "Info"
91|  }
92|]
93|```
94|
95|Targeting guidance:
96|
97|- `paragraph`: 1-based paragraph index.
98|- `section` + `page`: section/heading based placement.
99|- `quote`: phrase-level placement.
100|
101|Threading:
102|
103|- Use `parent_id` to reply to an existing comment. `parent_id` can reference a prior comment's `id` from the same JSON payload, or an existing numeric Word comment ID.
104|
105|Fields: `id` (optional), `parent_id` (optional), `page`, `paragraph`, `section`, `text`, `severity` (Critical/Major/Minor/Info), `status` (Open/Pending/Accepted/Rejected/Closed), `quote` (optional, for phrase-level placement).
106|
107|For comment pitfalls and compatibility (e.g. resolve requires Word 2013+), see **comments.md**.
108|
109|### Programmatic Text Extraction
110|
111|**When the view tool truncates or you need specific sections or later parts:** Use the methods below to read by paragraph/section or extract full text. View may truncate around ~2MB on full-document fallback/plaintext extraction; for long DOCX or targeted sections, use pandoc or python-docx. These text paths may miss embedded chart/image payloads; use rendered inspection for visual-only content.
112|
113|For quick tracked-change-aware extraction:
114|
115|```bash
116|pandoc --track-changes=all /root/workspace/file.docx -o /root/tmp/output.md
117|```
118|
119|For Python text extraction:
120|
121|```python
122|from docx import Document
123|
124|doc = Document('/root/workspace/file.docx')
125|for paragraph in doc.paragraphs:
126|    print(paragraph.text)
127|```
128|
129|### Creating and Editing with python-docx
130|
131|Use `python-docx` for simple, non-redline operations.
132|
133|```python
134|from docx import Document
135|
136|doc = Document()
137|doc.add_heading('Document Title', 0)
138|doc.add_paragraph('Body text')
139|doc.save('/root/workspace/output.docx')
140|```
141|
142|```python
143|from docx import Document
144|
145|doc = Document('/root/workspace/file.docx')
146|for paragraph in doc.paragraphs:
147|    if 'old text' in paragraph.text:
148|        for run in paragraph.runs:
149|            run.text = run.text.replace('old text', 'new text')
150|doc.save('/root/workspace/file.docx')
151|```
152|
153|### Review Workflow (Accept/Reject Changes)
154|
155|List tracked changes:
156|
157|```bash
158|python /root/skills/docx/scripts/list_changes.py /root/workspace/file.docx
159|```
160|
161|Accept all (in place):
162|
163|```bash
164|python /root/skills/docx/scripts/accept_all.py /root/workspace/file.docx
165|```
166|
167|Reject all (in place):
168|
169|```bash
170|python /root/skills/docx/scripts/reject_all.py /root/workspace/file.docx
171|```
172|
173|Fine-grained review (separate output):
174|
175|```bash
176|python /root/skills/docx/scripts/review.py /root/workspace/file.docx /root/workspace/output.docx
177|```
178|
179|Commands: `list | accept <id> | reject <id> | accept-all | reject-all | resolve <id> | delete <id> | save | quit`
180|
181|Verify clean state when needed:
182|
183|```bash
184|pandoc --track-changes=all /root/workspace/file.docx -o /root/tmp/verify.md
185|```
186|
187|## Advanced Workflows (OOXML and docx-js)
188|
189|Use advanced workflows only when the task needs precise layout control, tracked changes, native comment placement, or direct XML repair.
190|
191|### docx-js for New Documents
192|
193|Use `docx` (Node.js) when `python-docx` cannot express required layout/styling.
194|
195|- Read full patterns in `docx-js.md`.
196|- Always set page size explicitly (A4 is default).
197|- Use numbering config for lists (not literal bullet characters).
198|- Validate output:
199|
200|```bash

lines.offset/lines.limit are for plaintext/text-like files only. For PDF/Office docs use pages=[...] in text/visual mode.

[parsed_cache source=General Counsel/CrowdStrike GC Memo (v1).docx parsed_at=2026-02-24T16:46:31Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

--- PAGE 1 ---
Privileged & Confidential – Legal Department Memo

To:Board of Directors, CrowdStrike Holdings, Inc.

From: Legal Department

Date: November 14, 2025

Subject:Legal Update and Risk Posture Following July 2024 Outage (Channel 291)

I. Executive Summary

On July 19, 2024, CrowdStrike experienced a major outage caused by a faulty Falcon Sensor update, impacting over 8.5 million Windows systems globally and resulting in an estimated $10 billion in losses. This memo addresses three deliverables requested by the Board: (1) an update on litigation; (2) a review of the standard Master Subscription Agreement (MSA); and (3) legal concerns related to potential lawsuits from other parties, including shareholders.

II. Litigation Update

• Securities Class Action: Plymouth County Retirement Association v. CrowdStrike Holdings, Inc. alleges misleading statements regarding Falcon reliability and inadequate disclosure.

- o Filed July 30, 2024; class certification pending;

- o PSLRA discovery stay expected. Exposure is tied to market loss.

• Consumer Class Action: Airline passenger claims dismissed under ADA preemption (June 19, 2025), eliminating direct consumer exposure.

• Delta Airlines: Threatened breach-of-contract and negligence claims; other
enterprise customers exploring indemnification.

• Regulatory Risk: SEC scrutiny likely regarding disclosure adequacy and SOX certifications; potential informal inquiry escalating to formal investigation.

III. Review of Standard Customer Contract (MSA)

Current Strengths:

• Liability caps tied to fees paid; exclusion of consequential damages.

• Narrow warranties and disclaimers for critical infrastructure use.

• Customer obligations for updates and configuration.

Gaps Identified:

• Lack of explicit Rapid Response Content (RRC) risk allocation.

• Insufficient clarity on deployment obligations and rollback plans.

• Need to expand critical-environment carve-outs.

Recommended Updates:

1. Add an explicit RRC risk allocation clause.

2. Require staged rollout and rollback capability.


Note: Parsed text does not include chart data or embedded images. To see charts and images, use view(path="/root/workspace/General Counsel/CrowdStrike GC Memo (v1).docx", mode="visual", pages=[...]).

[parsed_cache source=Delta Litigation Case File/Ancillary Case_ Plymouth County Retirement v. CrowdStrike.   Consolidated to In Re Crowdstrike/In Re CrowdStrike Holdings Consolidated Class Action.pdf parsed_at=2026-03-03T13:00:09Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

--- PAGE 4 ---
Case 1:24-cv-00857-RP Document 41 Filed 01/21/25 Page 4 of 99

Lead Plaintiff Thomas P. DiNapoli, Comptroller of the State of New York, as Administrative Head of the New York State and Local Retirement System, and as Trustee of the New York State Common Retirement Fund (“New York State Common Retirement Fund”), by and through its undersigned counsel (“Lead Counsel”), brings this action under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”), and U.S. Securities and Exchange Commission (“SEC”) Rule 10b-5 promulgated thereunder, against Defendants CrowdStrike Holdings, Inc. (“CrowdStrike” or the “Company”), its Chief Executive Officer, George Kurtz (“Kurtz”), and its President, Michael Sentonas (“Sentonas”) (collectively, the “Defendants”), on behalf of itself and all other similarly situated persons or entities who purchased or otherwise acquired CrowdStrike common stock between September 20, 2022 and July 30, 2024, inclusive (the “Class Period”), and were damaged thereby (collectively, the “Class”).

I. INTRODUCTION

1. During the Class Period, CrowdStrike was one of the world’s fastest-growing cybersecurity companies. CrowdStrike secured contracts with the U.S. federal government, 43 state governments, and over half of all Fortune 500 companies to purchase its one and only product, CrowdStrike’s “Falcon” cybersecurity platform. According to CrowdStrike, what set Falcon apart from competing products was its “Rapid Response” updates, which were delivered silently to CrowdStrike’s customers through the “cloud” and included the latest threat detection code. While customers and investors applauded the functionality of Falcon’s software, they were concerned that its software updates may, themselves, be unstable because (unlike traditional software updates) the Rapid Response updates were installed on customers’ computers without notice. In response to these concerns, CrowdStrike, its CEO, Defendant Kurtz, and its President, Defendant Sentonas, represented over and over that it adhered to industry-standard testing and quality assurance requirements and, as a result, its updates were safe and reliable and would not cause

--- PAGE 92 ---
Case 1:24-cv-00857-RP Document 41 Filed 01/21/25 Page 92 of 99

redress the wrongs done to them. There will be no difficulty in the management of this action as a class action.

## COUNT I

## For Violations of Section 10(b) of the Exchange Act and SEC Rule 10b-5 Thereunder (Against All Defendants)

181. This Count is asserted on behalf of all members of the Class against all Defendants for violations of Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b) and Rule 10b-5 promulgated thereunder, 17 C.F.R. § 240.10b-5.

182. During the Class Period, Defendants disseminated, furnished information for inclusion in, or approved the false statements specified above, which they knew, or were severely reckless in not knowing, were false or misleading in that they contained misrepresentations and/or omitted material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading.

183. During the Class Period, Defendants carried out a plan, scheme, and course of conduct which was intended to and, throughout the Class Period, did: (i) deceive the investing public, including Lead Plaintiff and other Class members, as alleged herein; and (ii) cause Lead Plaintiff and other members of the Class to purchase CrowdStrike common stock at artificially inflated prices.

184. Defendants violated Section 10(b) of the Exchange Act and Rule 10b-5 in that they: (i) employed devices, schemes, and artifices to defraud; (ii) made untrue statements of material fact and/or omitted to state material facts necessary to make the statements not misleading; and (iii) engaged in acts, practices, and a course of business which operated as a fraud and deceit upon the purchasers of the Company's common stock in an effort to maintain artificially high market prices for CrowdStrike common stock.

--- PAGE 96 ---
Case 1:24-cv-00857-RP Document 41 Filed 01/21/25 Page 96 of 99

198. By virtue of their positions as controlling persons of CrowdStrike and as a result of their own aforementioned conduct, Defendants Kurtz and Sentonas were liable pursuant to Section 20(a) of the Exchange Act, jointly and severally with, and to the same extent as, the Company is liable under Section 10(b) of the Exchange Act and Rule 10b-5 promulgated thereunder, to Lead Plaintiff and the other members of the Class who purchased or otherwise acquired CrowdStrike securities.

199. As a direct and proximate result of Defendants Kurtz's and Sentonas's conduct, Lead Plaintiff and the other members of the Class suffered damages in connection with their purchase or acquisition of CrowdStrike common stock.

200. This claim is brought within the applicable statute of limitations.

## XII. PRAYER FOR RELIEF

201. WHEREFORE, Lead Plaintiff prays for judgment as follows:

a. Determining that this action is a proper class action under Rule 23 of the Federal Rules of Civil Procedure on behalf of the Class defined herein;

b. Awarding compensatory damages in favor of Lead Plaintiff and other Class members against Defendants, jointly and severally, for all damages sustained as a result of Defendants' wrongdoing, in an amount to be proven at trial, including interest thereon;

c. Awarding Lead Plaintiff and the Class their reasonable costs and expenses incurred in this action, including attorneys' fees and expert fees; and

d. Awarding such equitable, injunctive or other further relief as the Court may deem just and proper.

## XIII. JURY DEMAND

202. Lead Plaintiff hereby demands a trial by jury.

[parsed_cache source=SEC Counsel/Plymouth County Retirement Association CrowdStrike Class-Action Complaint.pdf parsed_at=2026-03-03T12:51:41Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

--- PAGE 2 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 2 of 29

## I. INTRODUCTION

Plaintiff Plymouth County Retirement Association (“Plaintiff”), individually and on behalf of all others similarly situated, allege the following based upon personal knowledge as to Plaintiff’s own acts and upon information and belief as to all other matters based on the investigation conducted by and through counsel, which included, among other things, a review of the public U.S. Securities and Exchange Commission (“SEC”) filings of CrowdStrike Holdings, Inc. (“CrowdStrike” or the “Company”), Company press releases, conference call transcripts, investor presentations, analyst and media reports, and other public reports and information regarding the Company. Plaintiff believes that substantial additional evidentiary support exists for the allegations set forth herein, which evidence will be developed after a reasonable opportunity for discovery.

## II. NATURE OF THE ACTION

1. This is a federal securities class action on behalf of a class of all persons and entities who purchased or otherwise acquired CrowdStrike Class A common stock between November 29, 2023 and July 29, 2024, inclusive (the “Class Period”), seeking to pursue remedies under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”), and SEC Rule 10b-5, promulgated thereunder.

2. CrowdStrike, headquartered in Austin, Texas, is a global cybersecurity company that provides software that helps prevent data breaches. CrowdStrike’s customers are major corporations across several industries including airlines, banks, hospitals, and telecommunications providers as well as government entities. CrowdStrike’s main product is the Falcon software platform, which purportedly uses artificial intelligence and machine learning technologies to detect, prevent, and respond to security breach threats. The Falcon software is embedded in the computers of CrowdStrike’s customers and requires constant updates.

--- PAGE 24 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 24 of 29

60. This Count is asserted against Defendants and is based upon Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5 promulgated thereunder by the SEC.

61. During the Class Period, Defendants disseminated or approved the false statements specified above, which they knew or recklessly disregarded were misleading in that they contained misrepresentations and failed to disclose material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading.

62. Defendants violated Section 10(b) of the Exchange Act and Rule 10b-5 in that they:

(a) Employed devices, schemes, and artifices to defraud;

(b) Made untrue statements of material facts or omitted to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; or

(c) Engaged in acts, practices, and a course of business that operated as a fraud or deceit upon Plaintiff and others similarly situated in connection with their purchases of CrowdStrike stock during the Class Period.

63. Plaintiff and the Class have suffered damages in that, in reliance on the integrity of the market, they paid artificially inflated prices for CrowdStrike stock. Plaintiff and the Class would not have purchased CrowdStrike stock at the prices they paid, or at all, if they had been aware that the market prices had been artificially and falsely inflated by Defendants' misleading statements.

64. As a direct and proximate result of these Defendants' wrongful conduct, Plaintiff and the other members of the Class suffered damages in connection with their purchases of CrowdStrike stock during the Class Period.

--- PAGE 25 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 25 of 29

65. By virtue of the foregoing, Defendants violated Section 10(b) of the Exchange Act and Rule 10b-5, promulgated thereunder.

## COUNT II

## Violations of Section 20(a) of the Exchange Act Against the Individual Defendants

66. Plaintiff repeats and realleges the allegations contained in ¶¶ 1-58 as if fully set forth herein.

67. The Individual Defendants acted as controlling persons of CrowdStrike within the meaning of Section 20(a) of the Exchange Act. By virtue of their positions and their power to control public statements about CrowdStrike, the Individual Defendants had the power and ability to control the actions of CrowdStrike and its employees. By reason of such conduct, Individual Defendants are liable pursuant to Section 20(a) of the Exchange Act.

## XIV. PRAYER FOR RELIEF

WHEREFORE, Plaintiff, individually and on behalf of the proposed Class, respectfully prays for judgment against Defendants as follows:

A. Determining that this action is a proper class action, designating Plaintiff as Lead Plaintiff and certifying Plaintiff as a class representative under Rule 23 of the Federal Rules of Civil Procedure and Plaintiff's counsel as Lead Counsel;

B. Awarding Plaintiff and the Class compensatory damages against all Defendants, jointly and severally, for all damages sustained as a result of Defendants' wrongdoing, in an amount to be proven at trial, together with pre-judgment interest thereon;

C. Awarding Plaintiff and the Class their reasonable costs and expenses incurred in this action, including, but not limited to, attorneys' fees and costs incurred by consulting and testifying expert witnesses; and

--- PAGE 27 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 27 of 29

# CERTIFICATION

I, Padraic P. Lydon, as Executive Director of Plymouth County Retirement Association ("Plymouth County"), hereby certify as follows:

1. I am fully authorized to enter into and execute this Certification on behalf of Plymouth County. I have reviewed a complaint prepared against CrowdStrike Holdings, Inc. ("CrowdStrike") alleging violations of the federal securities laws and authorize the filing of this pleading;

2. Plymouth County did not purchase Class A common stock of CrowdStrike at the direction of counsel or in order to participate in any private action under the federal securities laws;

3. Plymouth County is willing to serve as a lead plaintiff and representative party in this matter, including providing testimony at deposition and trial, if necessary. Plymouth County fully understands the duties and responsibilities of the lead plaintiff under the Private Securities Litigation Reform Act, including the selection and retention of counsel and overseeing the prosecution of the action for the Class;

4. Plymouth County's transactions in CrowdStrike Class A common stock during the Class Period are reflected in Exhibit A, attached hereto;

5. Plymouth County sought to serve as a lead plaintiff or representative party in the following class actions filed under the federal securities laws during the last three years:

Plymouth County Retirement Association v. AppHarvest, Inc., No. 1:21-cv-09676 (S.D.N.Y.)
In re Astra Space Inc. f/k/a Holicity Inc. Securities Litigation, No. 3:22-cv-08875 (N.D. Cal.)
Plymouth County Retirement Association v. Upstart Holdings, Inc. No. 3:22-cv-02973 (N.D. Cal.) (filing plaintiff)
Plymouth County Retirement Association v. Outset Medical, Inc., No. 3:22-cv-04016 (N.D. Cal.) (filing plaintiff)

6. Beyond its pro rata share of any recovery, Plymouth County will not accept payment for serving as a lead plaintiff and representative party on behalf of the Class, except the reimbursement of such reasonable costs and expenses (including lost wages) as ordered or approved by the Court.

[parsed_cache source=Delta Litigation Case File/Legal Memos/LEGAL BRIEF_ Shareholder Litigation Risk Analysis — CrowdStrike July 2024 Outage.docx parsed_at=2026-03-03T12:57:44Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

--- PAGE 1 ---
LEGAL BRIEF: Shareholder Litigation Risk Analysis — CrowdStrike July 2024 Outage

Prepared for: General Counsel, CrowdStrike Holdings, Inc. Prepared by: Outside Counsel Date: November 2025 Subject: Litigation Status, Contractual Protections, and Shareholder-Lawsuit Exposure under the CrowdStrike MSA (v. 2022)

I. Background

OnJuly 19 2024, CrowdStrike deployed an automatic Falcon Sensorupdate containing a defect that rendered millions of Windows systems unbootable. The failure cascaded through mission-critical infrastructure worldwide, grounding airlines, disrupting healthcare networks, and halting logistics operations. Global economic losses were estimated at $10 billion.

CrowdStrike’s rapid rollback and customer support limited long-term impact but generated substantial litigation exposure. Delta Air Lines and other enterprise clients filed suits alleging breach of contract and negligence, while several shareholder and derivative complaints assert that management misrepresented risk controls and failed to exercise adequate board oversight.

II. Update on Current Litigation

A. Commercial Suits

● Delta Air Lines v. CrowdStrike (N.D. Ga.)— breach of contract and
negligence.

○ Delta’s claims: the defective update caused operational paralysis, flight cancellations, and reputational damage.

○ CrowdStrike’s response: invokes contractual defenses under the MSA, including the Section 10 limitation of liability,warranty disclaimers (Section 8), and force-majeure clause (Section 14.6). CrowdStrike counter-claims that Delta’s environment violated integration guidelines and failed to maintain redundancy.

○ Status: motions to dismiss tort claims pending; discovery limited to causation and damages.


--- PAGE 2 ---
B. Other Customer Actions

Multiple class actions and international proceedings remain at the pleading stage. Most U.S. contracts include the MSA’s California law / Santa Clara venue clause (Section 14.1)andarbitration provisions, allowing early consolidation and limitation of exposure.

C. Shareholder & Derivative Actions

At least two putative class actions (filed in Delaware Chancery and N.D. Cal.) allege securities fraud under Exchange Act § 10(b)andRule 10b-5, and breach of fiduciary duty by directors under a Caremark-type oversight theory.

III. Contractual Analysis — CrowdStrike MSA (v. 2022)

TheMaster Subscription Agreement, publicly filed on the UK Digital Marketplace in 2022, governs most enterprise customer relationships. The following provisions are most relevant to the outage.

1. Limitation of Liability (Section 10)

“Neither party shall be liable for any lost profits, revenue, or savings, lost business opportunities, lost data, or special, incidental, consequential, or punitive damages … in excess of the total fees paid or payable … during the relevant Subscription Term.”

Impact:

This clause sharply limits exposure by capping total liability at roughly one year’s subscription fees and excluding consequential damages. It provides a strong defense in suits like Delta’s.

Risk:

Plaintiffs will argue that the outage constitutes gross negligence or willful misconduct, which many jurisdictions treat as exceptions to liability caps. Courts sometimes invalidate such limitations when failures affect critical infrastructure or safety systems.

2. Warranties & Disclaimers (Section 8)

CrowdStrike warrants that the Product will operate without “Error” and that it has used industry-standard techniques to prevent malicious software.

All other warranties are disclaimed, including any guarantee of uninterrupted or error-free operation; the Offerings are “not fault-tolerant.”


--- PAGE 3 ---
Impact:

The “operate without Error” language could anchor a breach-of-warrantyclaim, while the disclaimers substantially narrow liability.

Risk: Courts may find this dual structure ambiguous: customers can claim the warranty was breached; CrowdStrike counters that the exclusive remedy is correction or refund (Section 8.2). The limited-remedy framework could be challenged as unconscionable given the scale of the losses.

3. Exclusive Remedy (Section 8.2)

If a Product fails to meet the warranty, CrowdStrike’s sole obligation is to (a) use commercially reasonable efforts to correct the Error or (b) terminate the license and refund prepaid fees.

Impact: Highly protective, but impractical in a systemic outage. A single-refund remedy for a global service failure could be deemed inadequate consideration and might not preclude claims for broader damages if the failure is deemed fundamental.

4. Force Majeure (Section 14.6)

CrowdStrike is not liable for performance failures caused by circumstances beyond its reasonable control, including “outage of communications … networked environment.”

Impact: Intended to shield against third-party disruptions, not internal code defects. Because the outage stemmed from CrowdStrike’s own update, this defense is weak. Overuse may appear disingenuous and harm credibility before regulators and shareholders.

5. Governing Law & Venue (Section 14.1)

California law; exclusive venue in Santa Clara County.

Impact: Ensures predictability and access to a favorable forum that generally enforces sophisticated commercial limitations, improving litigation posture in U.S. suits.

6. Data-Security Obligations (Exhibit A)


Note: Parsed text does not include chart data or embedded images. To see charts and images, use view(path="/root/workspace/Delta Litigation Case File/Legal Memos/LEGAL BRIEF_ Shareholder Litigation Risk Analysis — CrowdStrike July 2024 Outage.docx", mode="visual", pages=[...]).

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No matches found.

## Grep Results (Files with matches)

Matches: 1 (offset=0, limit=50)
Files: 1

### 1
- file_path: Stock Transactions.xlsx

## Sources Freshness

- Stock Transactions.xlsx (parsed_at: 2026-03-16T09:52:57Z, source_updated_at: 2026-03-16T09:52:46Z)

## Grep Results (Files with matches)

Matches: 4 (offset=0, limit=50)
Files: 4

### 1
- file_path: SEC Counsel/Moving Slow and Fixing Things.pdf

### 2
- file_path: SEC Counsel/CrowdStrike Form 10-K 2025.pdf

### 3
- file_path: SEC Counsel/CrowdStrike Form 10-K 2024.pdf

### 4
- file_path: Delta Litigation Case File/Case and Statutory Law/Law for Legal Research Overview Two/Community State Bank v Strong.pdf

## Sources Freshness

- Delta Litigation Case File/Case and Statutory Law/Law for Legal Research Overview Two/Community State Bank v Strong.pdf (parsed_at: 2026-03-03T13:00:11Z, source_updated_at: 2026-03-14T15:09:59Z)
- SEC Counsel/CrowdStrike Form 10-K 2024.pdf (parsed_at: 2026-02-24T16:39:05Z, source_updated_at: 2026-03-14T15:09:59Z)
- SEC Counsel/CrowdStrike Form 10-K 2025.pdf (parsed_at: 2026-02-24T16:42:49Z, source_updated_at: 2026-03-14T15:09:59Z)
- SEC Counsel/Moving Slow and Fixing Things.pdf (parsed_at: 2026-03-03T12:52:23Z, source_updated_at: 2026-03-14T15:09:59Z)

## File Search Results

Found: 50 (limit=50)

1. Delta Litigation Case File/Discovery/Requests for Production/Plaintiff Delta Air Lines, Inc.’s First Request for Production of Documents and Defendant CrowdStrike Holdings, Inc.’s Responses and Objections
2. Delta Litigation Case File/Discovery/Interrogatories/Plaintiff Delta Air Lines, Inc.’s First Set of Interrogatories to Defendant CrowdStrike Holdings, Inc_
3. Delta Litigation Case File/Discovery/Deposition Excerpts/Michael Anders, Chief Information Security Officer (CISO), CrowdStrike Holdings, Inc. Deposition
4. General Counsel/Documents Received from SEC Counsel/Crowdstrike Class action complaint.pdf
5. Delta Litigation Case File/Discovery/Interrogatories/Defendant CrowdStrike Holdings, Inc.’s Responses and Objections to Plaintiff Delta Air Lines, Inc.’s First Set of Interrogatories
6. SEC Counsel/CrowdStrike Form 10-K 2024.pdf
7. Delta Litigation Case File/Outline of legal concerns re potential lawsuits. Version 1/Legal Concerns of Potential CrowdStrike Lawsuits- Version One.docx
8. Delta Litigation Case File/Ancillary Case_ Plymouth County Retirement v. CrowdStrike.   Consolidated to In Re Crowdstrike/In Re CrowdStrike Holdings Consolidated Class Action.pdf
9. Delta Litigation Case File/Discovery/Produced Documents/Email Chain (Delta–CrowdStrike Crisis Communications).docx
10. Delta Litigation Case File/Discovery/Requests for Admissions/Defendant CrowdStrike Holdings, Inc.’s Responses and Objections to Plaintiff’s First Set of Requests for Admission
11. Delta Litigation Case File/Ancillary Case_ Plymouth County Retirement v. CrowdStrike.   Consolidated to In Re Crowdstrike/Plymouth County v CrowdStrike-Complaint.pdf
12. Delta Litigation Case File/Outline of legal concerns re potential lawsuits. Version 1/Legal Concerns of Potential CrowdStrike Lawsuits- Version One (1).pdf
13. Delta Litigation Case File/Legal Memos/Memo Potential Passenger Lawsuits Against CrowdStrike Arising from Delta Air Lines_.docx
14. Delta Litigation Case File/Ancillary Case_ del Rio v. Crowdstrike/Del Rio v Crowdstrike order on mtd.pdf
15. Delta Litigation Case File/Legal Memos/LEGAL BRIEF_ Shareholder Litigation Risk Analysis — CrowdStrike July 2024 Outage.docx
16. Delta Litigation Case File/Ancillary Case_ del Rio v. Crowdstrike/Del Rio v Crowdstrike Complaint.pdf
17. Delta Litigation Case File/Rule 11 Motion/CrowdStrike’s Response Letter Rule 11.docx
18. Delta Litigation Case File/Ancillary Case_ Plymouth County Retirement v. CrowdStrike.   Consolidated to In Re Crowdstrike/CROWDSTRIKE MOTION TO DISMISS- UPDATED IN RE CROWDSTRIKE.pdf
19. General Counsel/Documents Received from SEC Counsel/CrowdStrike Article on Consumer Class Action Dismissal.pdf
20. Delta Litigation Case File/Ancillary Case_ del Rio v. Crowdstrike/Crowdstrike press release re dismissal of airline passengers classaction.pdf
21. Delta Litigation Case File/Legal Memos/CrowdStrike Litigation SUmmary and Update Final (1).pdf
22. Delta Litigation Case File/Legal Memos/CrowdStrike Litigation SUmmary and Update Final.docx
23. Delta Litigation Case File/Legal Memos/CrowdStrike Litigation Summary and Update Memo.pdf
24. Delta Litigation Case File/Insurance Denial Letter and Correspondence/Crowdstrike Notice of Claim and Tender of Defense – July 19 2024 Global Outage.docx
25. SEC Counsel/To Our Customers and Partners _ CrowdStrike.pdf
26. SEC Counsel/U.S. District Court Dismisses Class Action Lawsuit Against CrowdStrike
27. SEC Counsel/Rough Draft of Memorandum to CrowdStrike.pdf
28. General Counsel/CrowdStrike GC Memo (v1).docx
29. SEC Counsel/Plymouth County Retirement Association CrowdStrike Class-Action Complaint.pdf
30. Delta Litigation Case File/Order on crowdstrike_s Motion to Dismiss.pdf
31. SEC Counsel/Impact of CrowdStrike Outage on Delta Airlines.pdf
32. Delta Litigation Case File/Delta-v-CrowdStrike-Complaint-10-25-24.pdf
33. General Counsel/Falcon Content Update Preliminary Post Incident Report _ CrowdStrike.pdf
34. Delta Litigation Case File/Events and Hearings- Delta v. Crowdstrike
35. Delta Litigation Case File/Delta v. Crowdstrike - SUMMONS
36. Delta Litigation Case File/Delta press release re crowdstrike outage.pdf
37. Delta Litigation Case File/Delta v Crowdstrike- ORDER TRANSFER OPEN CASE.pdf
38. Delta Litigation Case File/Delta v. Crowdstrike - AFFIDAVIT OF SERVICE
39. Delta Litigation Case File/CrowdStrike-v-Delta-Complaint-10-25-24.pdf
40. SEC Counsel/CrowdStrike Article on Consumer Class Action Dismissal.pdf
41. Commercial Counsel/CrowdStrike MSA.pdf
42. Delta Litigation Case File/CrowdStrike-Post Incident Analysis.pdf
43. SEC Counsel/CrowdStrike Bi-laws.pdf
44. SEC Counsel/CrowdStrike Form 8-K 2024.pdf
45. General Counsel/CrowdStrike Final Legal Memo (v2).docx
46. Delta Litigation Case File/CrowdStrike U.S. Cases and Investigations Timeline
47. SEC Counsel/Crowdstrike Shareholder Lawsuit_1.pdf
48. Delta Litigation Case File/Crowdstrike-Airline-Passengers-complaint (Case has been dismissed).pdf
49. Delta Litigation Case File/CROWDSTRIKE LITIGATION CASES PERTAINING TO OUTAGE.pdf
50. SEC Counsel/CrowdStrike Securities Class Action Complaint.pdf

Showing first results only. Narrow your pattern or specify a path.

## File Search Results

Found: 9 (limit=50)

1. General Counsel/Documents Received from SEC Counsel/Crowdstrike Class action complaint.pdf
2. Delta Litigation Case File/Ancillary Case_ Plymouth County Retirement v. CrowdStrike.   Consolidated to In Re Crowdstrike/Plymouth County v CrowdStrike-Complaint.pdf
3. Delta Litigation Case File/Ancillary Case_ del Rio v. Crowdstrike/Del Rio v Crowdstrike Complaint.pdf
4. Delta Litigation Case File/Ancillary Case_ Bajra v. Delta/Bajra v Delta Complaint.pdf
5. SEC Counsel/Plymouth County Retirement Association CrowdStrike Class-Action Complaint.pdf
6. Delta Litigation Case File/Delta-v-CrowdStrike-Complaint-10-25-24.pdf
7. Delta Litigation Case File/CrowdStrike-v-Delta-Complaint-10-25-24.pdf
8. Delta Litigation Case File/Crowdstrike-Airline-Passengers-complaint (Case has been dismissed).pdf
9. SEC Counsel/CrowdStrike Securities Class Action Complaint.pdf

No files found.

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[parsed_cache source=Delta Litigation Case File/Ancillary Case_ Plymouth County Retirement v. CrowdStrike.   Consolidated to In Re Crowdstrike/Plymouth County v CrowdStrike-Complaint.pdf parsed_at=2026-03-03T12:58:49Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

--- PAGE 1 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 1 of 29

# UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION

|  PLYMOUTH COUNTY RETIREMENT ASSOCIATION, Individually and on Behalf of All Others Similarly Situated,

Plaintiff,

v.

CROWDSTRIKE HOLDINGS, INC., GEORGE KURTZ, and BURT W. PODBERE,

Defendants. | Civil Action No. 24-cv-857

CLASS ACTION

DEMAND FOR JURY TRIAL  |
| --- | --- |

CLASS ACTION COMPLAINT FOR VIOLATIONS
OF THE FEDERAL SECURITIES LAW

--- PAGE 2 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 2 of 29

## I. INTRODUCTION

Plaintiff Plymouth County Retirement Association (“Plaintiff”), individually and on behalf of all others similarly situated, allege the following based upon personal knowledge as to Plaintiff’s own acts and upon information and belief as to all other matters based on the investigation conducted by and through counsel, which included, among other things, a review of the public U.S. Securities and Exchange Commission (“SEC”) filings of CrowdStrike Holdings, Inc. (“CrowdStrike” or the “Company”), Company press releases, conference call transcripts, investor presentations, analyst and media reports, and other public reports and information regarding the Company. Plaintiff believes that substantial additional evidentiary support exists for the allegations set forth herein, which evidence will be developed after a reasonable opportunity for discovery.

## II. NATURE OF THE ACTION

1. This is a federal securities class action on behalf of a class of all persons and entities who purchased or otherwise acquired CrowdStrike Class A common stock between November 29, 2023 and July 29, 2024, inclusive (the “Class Period”), seeking to pursue remedies under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”), and SEC Rule 10b-5, promulgated thereunder.

2. CrowdStrike, headquartered in Austin, Texas, is a global cybersecurity company that provides software that helps prevent data breaches. CrowdStrike’s customers are major corporations across several industries including airlines, banks, hospitals, and telecommunications providers as well as government entities. CrowdStrike’s main product is the Falcon software platform, which purportedly uses artificial intelligence and machine learning technologies to detect, prevent, and respond to security breach threats. The Falcon software is embedded in the computers of CrowdStrike’s customers and requires constant updates.

--- PAGE 3 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 3 of 29

3. Throughout the Class Period, Defendants (defined herein) repeatedly touted the efficacy of the Falcon platform while assuring investors that CrowdStrike's technology was "validated, tested, and certified." This complaint alleges that these statements were false and misleading because Defendants had failed to disclose that: (1) CrowdStrike had instituted deficient controls in its procedure for updating Falcon and was not properly testing updates to Falcon before rolling them out to customers; (2) this inadequate software testing created a substantial risk that an update to Falcon could cause major outages for a significant number of the Company's customers; and (3) such outages could pose, and in fact ultimately created, substantial reputational harm and legal risk to CrowdStrike. As a result of these materially false and misleading statements and omissions, CrowdStrike stock traded at artificially high prices during the Class Period.

4. Beginning on July 19, 2024, investors learned about critical issues with CrowdStrike's technology when a single update pushed by CrowdStrike caused outages for millions of users of Microsoft Windows devices worldwide, including financial institutions, government entities, and corporations (the "CrowdStrike Outage"). Further, CrowdStrike disclosed that the outages had left users vulnerable to potential hacking threats. On this news, shares of CrowdStrike fell $38.09, or 11%, to close at $304.96 on July 19, 2024.

5. Then, on July 22, 2024, the fallout of the CrowdStrike outage was further revealed as Congress called on Defendant Kurtz to testify regarding the crisis and the Company's stock rating was downgraded by analysts such as Guggenheim and BTIG. On this news, shares of CrowdStrike fell $41.05, or 13.5%, to close at $263.91 on July 22, 2024.

6. Investors continued to learn about the legal risk Defendants had concealed on July 29, 2024, as news outlets reported that Delta Air Lines had hired prominent attorney David Boies

--- PAGE 4 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 4 of 29

to seek damages from the Company following the CrowdStrike Outage. On this news, shares of CrowdStrike fell $25.16, or 10%, to close at $233.65 on July 30, 2024.

7. These stock declines following the disclosure of Defendants’ fraud caused substantial damages to the Company’s investors.

8. Since the CrowdStrike Outage, public commentary from cybersecurity experts has provided evidence that CrowdStrike was taking insufficient precautions regarding such updates, including running insufficient tests.

## III. JURISDICTION AND VENUE

9. The claims asserted herein arise under and pursuant to Sections 10(b) and 20(a) of the Exchange Act, 15 U.S.C. §§ 78j(b) and 78t(a), and Rule 10b-5 promulgated thereunder by the SEC, 17 C.F.R. § 240.10b-5.

10. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. § 1331 and Section 27 of the Exchange Act, 15 U.S.C. § 78aa.

11. Venue is proper in this District under Section 27 of the Exchange Act, 15 U.S.C. § 78aa, and 28 U.S.C. § 1391(b), because CrowdStrike is headquartered in this District, and because many of the acts and conduct that constitute the violations of law complained of herein, including the dissemination to the public of materially false and misleading information, occurred in this District.

12. In connection with the acts alleged in this complaint, Defendants, directly or indirectly, used the means and instrumentalities of interstate commerce, including, but not limited to, the mails, interstate telephone communications, and the facilities of the national securities markets.

[parsed_cache source=SEC Counsel/CrowdStrike Securities Class Action Complaint.pdf parsed_at=2026-02-24T16:52:34Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

--- PAGE 1 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 1 of 29

# UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION

|  PLYMOUTH COUNTY RETIREMENT ASSOCIATION, Individually and on Behalf of All Others Similarly Situated,

Plaintiff,

v.

CROWDSTRIKE HOLDINGS, INC., GEORGE KURTZ, and BURT W. PODBERE,

Defendants. | Civil Action No. 24-cv-857

CLASS ACTION

DEMAND FOR JURY TRIAL  |
| --- | --- |

CLASS ACTION COMPLAINT FOR VIOLATIONS
OF THE FEDERAL SECURITIES LAW

--- PAGE 2 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 2 of 29

## I. INTRODUCTION

Plaintiff Plymouth County Retirement Association (“Plaintiff”), individually and on behalf of all others similarly situated, allege the following based upon personal knowledge as to Plaintiff’s own acts and upon information and belief as to all other matters based on the investigation conducted by and through counsel, which included, among other things, a review of the public U.S. Securities and Exchange Commission (“SEC”) filings of CrowdStrike Holdings, Inc. (“CrowdStrike” or the “Company”), Company press releases, conference call transcripts, investor presentations, analyst and media reports, and other public reports and information regarding the Company. Plaintiff believes that substantial additional evidentiary support exists for the allegations set forth herein, which evidence will be developed after a reasonable opportunity for discovery.

## II. NATURE OF THE ACTION

1. This is a federal securities class action on behalf of a class of all persons and entities who purchased or otherwise acquired CrowdStrike Class A common stock between November 29, 2023 and July 29, 2024, inclusive (the “Class Period”), seeking to pursue remedies under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”), and SEC Rule 10b-5, promulgated thereunder.

2. CrowdStrike, headquartered in Austin, Texas, is a global cybersecurity company that provides software that helps prevent data breaches. CrowdStrike’s customers are major corporations across several industries including airlines, banks, hospitals, and telecommunications providers as well as government entities. CrowdStrike’s main product is the Falcon software platform, which purportedly uses artificial intelligence and machine learning technologies to detect, prevent, and respond to security breach threats. The Falcon software is embedded in the computers of CrowdStrike’s customers and requires constant updates.

--- PAGE 3 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 3 of 29

3. Throughout the Class Period, Defendants (defined herein) repeatedly touted the efficacy of the Falcon platform while assuring investors that CrowdStrike's technology was "validated, tested, and certified." This complaint alleges that these statements were false and misleading because Defendants had failed to disclose that: (1) CrowdStrike had instituted deficient controls in its procedure for updating Falcon and was not properly testing updates to Falcon before rolling them out to customers; (2) this inadequate software testing created a substantial risk that an update to Falcon could cause major outages for a significant number of the Company's customers; and (3) such outages could pose, and in fact ultimately created, substantial reputational harm and legal risk to CrowdStrike. As a result of these materially false and misleading statements and omissions, CrowdStrike stock traded at artificially high prices during the Class Period.

4. Beginning on July 19, 2024, investors learned about critical issues with CrowdStrike's technology when a single update pushed by CrowdStrike caused outages for millions of users of Microsoft Windows devices worldwide, including financial institutions, government entities, and corporations (the "CrowdStrike Outage"). Further, CrowdStrike disclosed that the outages had left users vulnerable to potential hacking threats. On this news, shares of CrowdStrike fell $38.09, or 11%, to close at $304.96 on July 19, 2024.

5. Then, on July 22, 2024, the fallout of the CrowdStrike outage was further revealed as Congress called on Defendant Kurtz to testify regarding the crisis and the Company's stock rating was downgraded by analysts such as Guggenheim and BTIG. On this news, shares of CrowdStrike fell $41.05, or 13.5%, to close at $263.91 on July 22, 2024.

6. Investors continued to learn about the legal risk Defendants had concealed on July 29, 2024, as news outlets reported that Delta Air Lines had hired prominent attorney David Boies

--- PAGE 4 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 4 of 29

to seek damages from the Company following the CrowdStrike Outage. On this news, shares of CrowdStrike fell $25.16, or 10%, to close at $233.65 on July 30, 2024.

7. These stock declines following the disclosure of Defendants’ fraud caused substantial damages to the Company’s investors.

8. Since the CrowdStrike Outage, public commentary from cybersecurity experts has provided evidence that CrowdStrike was taking insufficient precautions regarding such updates, including running insufficient tests.

## III. JURISDICTION AND VENUE

9. The claims asserted herein arise under and pursuant to Sections 10(b) and 20(a) of the Exchange Act, 15 U.S.C. §§ 78j(b) and 78t(a), and Rule 10b-5 promulgated thereunder by the SEC, 17 C.F.R. § 240.10b-5.

10. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. § 1331 and Section 27 of the Exchange Act, 15 U.S.C. § 78aa.

11. Venue is proper in this District under Section 27 of the Exchange Act, 15 U.S.C. § 78aa, and 28 U.S.C. § 1391(b), because CrowdStrike is headquartered in this District, and because many of the acts and conduct that constitute the violations of law complained of herein, including the dissemination to the public of materially false and misleading information, occurred in this District.

12. In connection with the acts alleged in this complaint, Defendants, directly or indirectly, used the means and instrumentalities of interstate commerce, including, but not limited to, the mails, interstate telephone communications, and the facilities of the national securities markets.

[parsed_cache source=General Counsel/Documents Received from SEC Counsel/Crowdstrike Class action complaint.pdf parsed_at=2026-03-03T12:56:28Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

--- PAGE 1 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 1 of 29

# UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION

|  PLYMOUTH COUNTY RETIREMENT ASSOCIATION, Individually and on Behalf of All Others Similarly Situated,

Plaintiff,

v.

CROWDSTRIKE HOLDINGS, INC., GEORGE KURTZ, and BURT W. PODBERE,

Defendants. | Civil Action No. 24-cv-857

CLASS ACTION

DEMAND FOR JURY TRIAL  |
| --- | --- |

CLASS ACTION COMPLAINT FOR VIOLATIONS
OF THE FEDERAL SECURITIES LAW

--- PAGE 2 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 2 of 29

## I. INTRODUCTION

Plaintiff Plymouth County Retirement Association (“Plaintiff”), individually and on behalf of all others similarly situated, allege the following based upon personal knowledge as to Plaintiff’s own acts and upon information and belief as to all other matters based on the investigation conducted by and through counsel, which included, among other things, a review of the public U.S. Securities and Exchange Commission (“SEC”) filings of CrowdStrike Holdings, Inc. (“CrowdStrike” or the “Company”), Company press releases, conference call transcripts, investor presentations, analyst and media reports, and other public reports and information regarding the Company. Plaintiff believes that substantial additional evidentiary support exists for the allegations set forth herein, which evidence will be developed after a reasonable opportunity for discovery.

## II. NATURE OF THE ACTION

1. This is a federal securities class action on behalf of a class of all persons and entities who purchased or otherwise acquired CrowdStrike Class A common stock between November 29, 2023 and July 29, 2024, inclusive (the “Class Period”), seeking to pursue remedies under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”), and SEC Rule 10b-5, promulgated thereunder.

2. CrowdStrike, headquartered in Austin, Texas, is a global cybersecurity company that provides software that helps prevent data breaches. CrowdStrike’s customers are major corporations across several industries including airlines, banks, hospitals, and telecommunications providers as well as government entities. CrowdStrike’s main product is the Falcon software platform, which purportedly uses artificial intelligence and machine learning technologies to detect, prevent, and respond to security breach threats. The Falcon software is embedded in the computers of CrowdStrike’s customers and requires constant updates.

--- PAGE 3 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 3 of 29

3. Throughout the Class Period, Defendants (defined herein) repeatedly touted the efficacy of the Falcon platform while assuring investors that CrowdStrike's technology was "validated, tested, and certified." This complaint alleges that these statements were false and misleading because Defendants had failed to disclose that: (1) CrowdStrike had instituted deficient controls in its procedure for updating Falcon and was not properly testing updates to Falcon before rolling them out to customers; (2) this inadequate software testing created a substantial risk that an update to Falcon could cause major outages for a significant number of the Company's customers; and (3) such outages could pose, and in fact ultimately created, substantial reputational harm and legal risk to CrowdStrike. As a result of these materially false and misleading statements and omissions, CrowdStrike stock traded at artificially high prices during the Class Period.

4. Beginning on July 19, 2024, investors learned about critical issues with CrowdStrike's technology when a single update pushed by CrowdStrike caused outages for millions of users of Microsoft Windows devices worldwide, including financial institutions, government entities, and corporations (the "CrowdStrike Outage"). Further, CrowdStrike disclosed that the outages had left users vulnerable to potential hacking threats. On this news, shares of CrowdStrike fell $38.09, or 11%, to close at $304.96 on July 19, 2024.

5. Then, on July 22, 2024, the fallout of the CrowdStrike outage was further revealed as Congress called on Defendant Kurtz to testify regarding the crisis and the Company's stock rating was downgraded by analysts such as Guggenheim and BTIG. On this news, shares of CrowdStrike fell $41.05, or 13.5%, to close at $263.91 on July 22, 2024.

6. Investors continued to learn about the legal risk Defendants had concealed on July 29, 2024, as news outlets reported that Delta Air Lines had hired prominent attorney David Boies

--- PAGE 4 ---
Case 1:24-cv-00857 Document 1 Filed 07/30/24 Page 4 of 29

to seek damages from the Company following the CrowdStrike Outage. On this news, shares of CrowdStrike fell $25.16, or 10%, to close at $233.65 on July 30, 2024.

7. These stock declines following the disclosure of Defendants’ fraud caused substantial damages to the Company’s investors.

8. Since the CrowdStrike Outage, public commentary from cybersecurity experts has provided evidence that CrowdStrike was taking insufficient precautions regarding such updates, including running insufficient tests.

## III. JURISDICTION AND VENUE

9. The claims asserted herein arise under and pursuant to Sections 10(b) and 20(a) of the Exchange Act, 15 U.S.C. §§ 78j(b) and 78t(a), and Rule 10b-5 promulgated thereunder by the SEC, 17 C.F.R. § 240.10b-5.

10. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. § 1331 and Section 27 of the Exchange Act, 15 U.S.C. § 78aa.

11. Venue is proper in this District under Section 27 of the Exchange Act, 15 U.S.C. § 78aa, and 28 U.S.C. § 1391(b), because CrowdStrike is headquartered in this District, and because many of the acts and conduct that constitute the violations of law complained of herein, including the dissemination to the public of materially false and misleading information, occurred in this District.

12. In connection with the acts alleged in this complaint, Defendants, directly or indirectly, used the means and instrumentalities of interstate commerce, including, but not limited to, the mails, interstate telephone communications, and the facilities of the national securities markets.

No matches found.

No matches found.

## Grep Results (Grouped by file)

Matches: 10 (offset=0, limit=100)
Groups: 10

### 1
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- match_count: 1
- pages: 63
- sample_matches:
  - [line 7, page 63] (C) Altering or Amending the Order. An order that grants or denies class certification may be altered or amended before final judgment.

### 2
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- match_count: 1
- pages: 2
- sample_matches:
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### 3
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- match_count: 1
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- sample_matches:
  - [line 15, page 3] - September 2024. •No consolidation order or class certification yet issued.

### 4
- file_path: General Counsel/Documents Received from SEC Counsel/Memorandum – Channel 291 Incident- Pending & Anticipated Legal Exposure.pdf
- match_count: 1
- pages: 2
- sample_matches:
  - [line 13, page 2] - No consolidation order or class certification yet issued.

### 5
- file_path: General Counsel/CrowdStrike GC Memo (v1).docx
- match_count: 1
- pages: 1
- sample_matches:
  - [line 19, page 1] - o Filed July 30, 2024; class certification pending;

### 6
- file_path: Delta Litigation Case File/Legal Memos/CrowdStrike Litigation Summary and Update Memo.pdf
- match_count: 1
- pages: 3
- sample_matches:
  - [line 11, page 3] Two derivative actions pending in the Northern District of California allege that the directors breached their fiduciary duties by failing to maintain adequate QA oversight. CrowdStrike has moved to consolidate these matters and to dismiss them under the business-judgment rule. No class certification has been sought, and the matters presently pose limited exposure.

### 7
- file_path: Delta Litigation Case File/Legal Memos/CrowdStrike Litigation SUmmary and Update Final.docx
- match_count: 1
- pages: 3
- sample_matches:
  - [line 13, page 3] Defense Posture: We have moved to consolidate these actions and to dismiss under the business judgment rule. No class certification has been sought to date.

### 8
- file_path: Delta Litigation Case File/Legal Memos/CrowdStrike Litigation SUmmary and Update Final (1).pdf
- match_count: 1
- pages: 3
- sample_matches:
  - [line 11, page 3] Defense Posture: We have moved to consolidate these actions and to dismiss under the business judgment rule. No class certification has been sought to date.

### 9
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- match_count: 1
- pages: 7
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  - [line 50, page 7] ● Challenge class certification on grounds of individual issues predominating

### 10
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- match_count: 1
- pages: 7
- sample_matches:
  - [line 31, page 7] - Challenge class certification on grounds of individual issues predominating

## Sources Freshness

- Delta Litigation Case File/Legal Memos/Analysis of Legal Exposure Final (1).pdf (parsed_at: 2026-03-03T12:55:13Z, source_updated_at: 2026-03-14T15:09:59Z)
- Delta Litigation Case File/Legal Memos/Analysis of Legal Exposure Final.docx (parsed_at: 2026-03-03T12:54:49Z, source_updated_at: 2026-03-14T15:09:59Z)
- Delta Litigation Case File/Legal Memos/CrowdStrike Litigation SUmmary and Update Final (1).pdf (parsed_at: 2026-03-03T12:56:43Z, source_updated_at: 2026-03-14T15:09:59Z)
- Delta Litigation Case File/Legal Memos/CrowdStrike Litigation SUmmary and Update Final.docx (parsed_at: 2026-03-03T12:56:44Z, source_updated_at: 2026-03-14T15:09:59Z)
- Delta Litigation Case File/Legal Memos/CrowdStrike Litigation Summary and Update Memo.pdf (parsed_at: 2026-03-03T12:56:51Z, source_updated_at: 2026-03-14T15:09:59Z)
- General Counsel/CrowdStrike GC Memo (v1).docx (parsed_at: 2026-02-24T16:46:31Z, source_updated_at: 2026-03-14T15:09:59Z)
- General Counsel/Documents Received from SEC Counsel/Memorandum – Channel 291 Incident- Pending & Anticipated Legal Exposure.pdf (parsed_at: 2026-03-03T12:58:06Z, source_updated_at: 2026-03-14T15:09:59Z)
- General Counsel/Memorandum – Channel 291 Incident- Pending & Anticipated Legal Exposure.docx (parsed_at: 2026-03-03T12:50:49Z, source_updated_at: 2026-03-14T15:09:59Z)
- SEC Counsel/Memorandum – Channel 291 Incident- Pending & Anticipated Legal Exposure.pdf (parsed_at: 2026-03-03T12:50:41Z, source_updated_at: 2026-03-14T15:09:59Z)
- SEC Counsel/federal-rules-of-civil-procedure.pdf (parsed_at: 2026-03-03T12:54:57Z, source_updated_at: 2026-03-14T15:09:59Z)

[parsed_cache source=Delta Litigation Case File/Legal Memos/CrowdStrike Litigation Summary and Update Memo.pdf parsed_at=2026-03-03T12:56:51Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

--- PAGE 1 ---
# Memorandum

To: CrowdStrike Holdings, Inc.
From: [Outside Litigation Counsel]
Date: October 2, 2025
Re: Comprehensive Update — Delta Air Lines v. CrowdStrike and Related Matters

## Executive Summary

CrowdStrike continues to defend against the federal action brought by Delta Air Lines arising from the July 19, 2024 Falcon Sensor outage. The case is advancing toward trial with fact discovery largely completed and expert reports exchanged. Although CrowdStrike acknowledges responsibility for the underlying coding defect, the principal disputes concern causation, damages, and the enforceability of the contractual limitation-of-liability provision. Delta’s deployment configuration significantly magnified its outage severity, which forms a central pillar of our causation defense. Parallel shareholder derivative matters, insurance coverage disputes, and limited regulatory inquiries continue to progress but do not materially alter the Company’s overall risk posture. Based on current developments, we recommend maintaining the existing litigation reserve of $30 million.

## I. Overview

This memorandum provides a comprehensive update regarding the litigation initiated by Delta Air Lines in the Northern District of Georgia, related shareholder and derivative actions pending in California, and the status of ongoing insurance and regulatory matters. The purpose is to inform the Board and senior leadership of the Company’s current exposure, the procedural posture of each matter, and our recommendations for the next phase of litigation and risk management.

## II. Procedural Posture

The matter titled Delta Air Lines, Inc. v. CrowdStrike Holdings, Inc., No. 1:24-cv-2389 (N.D. Ga.), is presently in the late stages of pre-trial litigation. Fact discovery is substantially complete, and the parties exchanged expert reports in September 2025. Trial is scheduled for April 2026. Delta asserts claims for breach of contract, negligence, and breach of warranty in connection with the July 19, 2024 Falcon Sensor update known as Channel File 291. CrowdStrike has asserted comparative negligence and invoked the

--- PAGE 2 ---
contractual limitation of liability set forth in Section 10 of the 2022 Master Services Agreement.

Discovery to date has included extensive written exchanges and document production, including CrowdStrike's technical logs, root-cause analysis, and Board briefings. Depositions concluded in August 2025, including testimony from CTO Thomas Burke, CISO Michael Anders, and Delta's Managing Director of IT Operations, Lisa Moreno. The Court has identified no issues of spoliation and expressly commended both parties for their cooperation concerning electronically stored information.

## III. Summary of Core Facts

The record reflects that the outage originated from an array-field mismatch embedded in Channel File 291, which produced memory-access errors across approximately 8.5 million Windows endpoints. Although the defect itself was uniform across affected systems, Delta experienced significantly greater operational disruption than peer customers. This heightened impact resulted from Delta's auto-update settings, which deployed the update across its entire enterprise environment without staging or load-testing. CrowdStrike's root-cause analysis acknowledges responsibility for the coding defect but disputes that the Company is legally accountable for the breadth of Delta's resulting losses.

Within ten days of the incident, CrowdStrike implemented corrective measures that included new compile-time validation checks and mandatory staged-deployment protocols for affected sensor channels.

## IV. Key Pending Issues

### A. Expert Testimony

The expert phase will be central to the causation and damages arguments. Delta's expert, Dr. Leonard Farley of Georgia Tech, asserts that standard schema-validation procedures should have detected the defect and that CrowdStrike's QA controls were inadequate. In contrast, CrowdStrike's expert, Dr. Priya Menon, concludes that Delta's configuration decisions — particularly the absence of staged deployment — amplified its downtime by a factor of six when compared to similarly situated customers. Expert depositions are scheduled for November 2025, and we anticipate that Dr. Menon's testimony will significantly reinforce the argument that Delta's own practices are the predominant cause of its claimed damages.

--- PAGE 3 ---
B. Insurance Coverage Dispute

IronPeak Insurance Co. denied coverage under the Technology Errors & Omissions Policy on August 15, 2024, relying on the contractual-liability exclusion. CrowdStrike sought reconsideration on August 28, 2024, and the parties will participate in mediation in December 2025. Successful resolution could allow the Company to recover up to $25 million in defense costs.

C. Rule 11 Correspondence

Delta informally threatened Rule 11 sanctions in August 2024 in response to statements made in CrowdStrike’s public filings. After careful review, we determined that no correction or withdrawal was warranted. The Court subsequently issued a Minute Order in September 2024 acknowledging heightened tensions between counsel but finding no sanctionable conduct.

D. Shareholder and Derivative Actions

Two derivative actions pending in the Northern District of California allege that the directors breached their fiduciary duties by failing to maintain adequate QA oversight. CrowdStrike has moved to consolidate these matters and to dismiss them under the business-judgment rule. No class certification has been sought, and the matters presently pose limited exposure.

E. Regulatory Inquiries

The SEC has requested copies of CrowdStrike’s disclosures related to the outage but has not initiated enforcement proceedings. Similarly, the U.K. ICO requested information in August 2024 regarding data-protection safeguards; CrowdStrike provided a fulsome response, and no further action has been taken.

V. Financial Exposure and Reserves

Delta seeks approximately $365 million in direct losses allegedly attributable to the outage. CrowdStrike maintains that the damages are substantially overstated and, in any event, are contractually capped at roughly $4.5 million pursuant to the 12-month subscription-fee limitation in the MSA. Defense costs now total approximately $18 million, including legal fees, expert work, and discovery-vendor costs. Subject to the outcome of the IronPeak mediation, up to $25 million in insurance reimbursement remains potentially available. We recommend maintaining the current $30 million reserve through the first quarter of FY2026.

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To: Andrew, General Counsel, CrowdStrike Holdings, Inc.
From: Ismuel and Chrisina SEC Counsel
Date: 11/13/2025
Re: Summary of Pending and Anticipated Litigation Related to Channel 291 Incident (July 2024 Outage)

# I. INTRODUCTION

This memorandum provides an overview of current and anticipated legal matters involving CrowdStrike Holdings, Inc. ("CrowdStrike" or "the Company") arising from the July 2024 outage known internally as the Channel 291 Incident. The analysis includes:

1. A summary of current pending securities litigation;
2. The status of consumer class action claims;
3. Other potential or threatened litigation; and
4. Anticipated SEC-related proceedings and forward-looking recommendations for disclosure and compliance posture.

All referenced filings are attached, including the Plymouth County Retirement Association v. CrowdStrike Holdings, Inc. federal securities class action complaint and the order dismissing the related consumer class action.

# II. PENDING SECURITIES CLASS ACTION

Case Title: Plymouth County Retirement Association v. CrowdStrike Holdings, Inc., et al.
Court: U.S. District Court, Western District of Texas (Austin Division)
Docket No.: 1:24-cv-00857
Filed: July 30, 2024
Plaintiff: Plymouth County Retirement Association
Defendants: CrowdStrike Holdings, Inc.; George Kurtz (CEO); Burt W. Podbere (CFO)
Counsel for Plaintiff: Labaton Keller Sucharow LLP
Claims: Violations of Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 and SEC Rule 10b-5

# A. Nature of the Claims

The complaint alleges that, between November 29, 2023, and July 29, 2024, CrowdStrike and its officers made materially false and misleading statements regarding the efficacy, testing, and reliability of the Falcon platform, and failed to disclose deficiencies in internal controls over product updates.

Specifically, plaintiffs claim that:

--- PAGE 2 ---
- The Company did not adequately test Falcon updates prior to release;
- These deficiencies created foreseeable risks of widespread outages;
- The Company’s risk-factor disclosures under Form 10-Q and Form 10-K were materially incomplete or misleading; and
- The July 2024 outage (“Channel 291 Incident”) revealed the undisclosed risks, causing significant market losses.

## B. Alleged Damages

Plaintiffs assert that CrowdStrike’s stock price declines—11% on July 19, 2024; 13.5% on July 22, 2024; and 10% on July 30, 2024—were the direct result of the alleged misrepresentations and subsequent corrective disclosures.

## C. Procedural Posture

- Complaint filed July 30, 2024; lead-plaintiff motions due mid-September 2024.
- No consolidation order or class certification yet issued.
- Attached: CrowdStrike Class Action Complaint.pdf

CrowdStrike Class action compla...

The Company has not yet been required to respond but should anticipate PSLRA discovery stays and early motion practice focused on dismissal and safe-harbor defenses.

## III. DISMISSED CONSUMER CLASS ACTION

Case Title: Unnamed Airline Passenger Plaintiffs v. CrowdStrike Holdings, Inc.
Court: U.S. District Court, Western District of Texas
Decision Date: June 19, 2025
Disposition: Dismissed with prejudice
Primary Legal Issue: Preemption under the Airline Deregulation Act (ADA)

## A. Summary of Decision

The consumer class action, filed by airline passengers alleging damages due to flight disruptions, was dismissed in its entirety. The Court held that the ADA expressly preempts all state-law claims related to airline services—even when the defendant is a third-party software vendor rather than an airline itself.

## B. Legal Significance

The ruling materially reduces consumer exposure risk by foreclosing state-law tort or contract claims connected to flight disruptions stemming from the Channel 291 incident.

--- PAGE 3 ---
C. Attachment: CrowdStrike Article on Consumer Class Action Dismissal.pdf

CrowdStrike Article on Consumer...

# IV. OTHER RELATED OR THREATENED LITIGATION

## A. Derivative / Shareholder Actions

No shareholder-derivative suits have been filed as of this date. However, such claims often follow the appointment of a lead plaintiff in securities class actions. Likely theories include alleged breach of fiduciary duty, waste of corporate assets, and failure to maintain adequate internal controls.

## B. Contractual and Commercial Claims

Media reports indicate that Delta Air Lines and several other enterprise clients have retained outside counsel to explore potential indemnification or breach-of-contract claims. These matters have not yet been filed or formally noticed.

## C. Regulatory or Agency Inquiries

No formal SEC, FTC, or other agency enforcement actions have been announced. However, preliminary contact from SEC Division of Enforcement staff remains a credible possibility given the timing of the outage and its market effects.

# V. ANTICIPATED SEC-RELATED LITIGATION AND ENFORCEMENT RISK

Given the scope of the outage, market volatility, and subsequent investor litigation, the Company should anticipate increased SEC scrutiny. Potential areas of concern and enforcement exposure include the following:

## A. Disclosure Adequacy

The SEC may review whether the Company’s public filings and risk disclosures under Regulation S-K Items 105 and 106 accurately described:

- Internal cybersecurity risk management procedures;
- The testing and release processes for Falcon updates; and
- The sufficiency and timing of post-incident disclosures.

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Rules of Civil Procedure

(A) Time to Issue. At an early practicable time after a person sues or is sued as a class representative, the court must determine by order whether to certify the action as a class action.

(B) Defining the Class; Appointing Class Counsel. An order that certifies a class action must define the class and the class claims, issues, or defenses, and must appoint class counsel under Rule 23(g).

(C) Altering or Amending the Order. An order that grants or denies class certification may be altered or amended before final judgment.

(2) Notice.

(A) For (b)(1) or (b)(2) Classes. For any class certified under Rule 23(b)(1) or (b)(2), the court may direct appropriate notice to the class.

(B) For (b)(3) Classes. For any class certified under Rule 23(b)(3)—or upon ordering notice under Rule 23(e)(1) to a class proposed to be certified for purposes of settlement under Rule 23(b)(3)—the court must direct to class members the best notice that is practicable under the circumstances, including individual notice to all members who can be identified through reasonable effort. The notice may be by one or more of the following: United States mail, electronic means, or other appropriate means. The notice must clearly and concisely state in plain, easily understood language:

(i) the nature of the action;

(ii) the definition of the class certified;

(iii) the class claims, issues, or defenses;

(iv) that a class member may enter an ap-

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Rules of Civil Procedure

pearance through an attorney if the member so desires;

(v) that the court will exclude from the class any member who requests exclusion;

(vi) the time and manner for requesting exclusion; and

(vii) the binding effect of a class judgment on members under Rule 23(c)(3).

(3) Judgment. Whether or not favorable to the class, the judgment in a class action must:

(A) for any class certified under Rule 23(b)(1) or (b)(2), include and describe those whom the court finds to be class members; and

(B) for any class certified under Rule 23(b)(3), include and specify or describe those to whom the Rule 23(c)(2) notice was directed, who have not requested exclusion, and whom the court finds to be class members.

(4) Particular Issues. When appropriate, an action may be maintained as a class action with respect to particular issues.

(5) Subclasses. When appropriate, a class may be divided into subclasses that are each treated as a class under this rule.

(d) Conducting the Action.

(1) In General. In conducting an action under this rule, the court may issue orders that:

(A) determine the course of proceedings or prescribe measures to prevent undue repetition or complication in presenting evidence or argument;

(B) require—to protect class members and fairly conduct the action—giving appropriate notice to some or all class members of:

(i) any step in the action;

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Rules of Civil Procedure

(ii) the proposed extent of the judgment; or
(iii) the members' opportunity to signify whether they consider the representation fair and adequate, to intervene and present claims or defenses, or to otherwise come into the action;
(C) impose conditions on the representative parties or on intervenors;
(D) require that the pleadings be amended to eliminate allegations about representation of absent persons and that the action proceed accordingly; or
(E) deal with similar procedural matters.

(2) Combining and Amending Orders. An order under Rule 23(d)(1) may be altered or amended from time to time and may be combined with an order under Rule 16.

(e) Settlement, Voluntary Dismissal, or Compromise. The claims, issues, or defenses of a certified class—or a class proposed to be certified for purposes of settlement—may be settled, voluntarily dismissed, or compromised only with the court's approval. The following procedures apply to a proposed settlement, voluntary dismissal, or compromise:

(1) Notice to the Class.

(A) Information That Parties Must Provide to the Court. The parties must provide the court with information sufficient to enable it to determine whether to give notice of the proposal to the class.
(B) Grounds for a Decision to Give Notice. The court must direct notice in a reasonable manner to all class members who would be bound by the proposal if giving notice is justified by the parties' showing that the court will likely be able to:

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Rules of Civil Procedure

(i) approve the proposal under Rule 23(e)(2); and
(ii) certify the class for purposes of judgment on the proposal.

(2) Approval of the Proposal. If the proposal would bind class members, the court may approve it only after a hearing and only on finding that it is fair, reasonable, and adequate after considering whether:

(A) the class representatives and class counsel have adequately represented the class;
(B) the proposal was negotiated at arm's length;
(C) the relief provided for the class is adequate, taking into account:

(i) the costs, risks, and delay of trial and appeal;
(ii) the effectiveness of any proposed method of distributing relief to the class, including the method of processing class-member claims;
(iii) the terms of any proposed award of attorney's fees, including timing of payment; and
(iv) any agreement required to be identified under Rule 23(e)(3); and

(D) the proposal treats class members equitably relative to each other.

(3) Identifying Agreements. The parties seeking approval must file a statement identifying any agreement made in connection with the proposal.

(4) New Opportunity to Be Excluded. If the class action was previously certified under Rule 23(b)(3), the court may refuse to approve a settlement unless it affords a new opportunity to request exclusion to

[parsed_cache source=Delta Litigation Case File/Legal Memos/Analysis of Legal Exposure Final.docx parsed_at=2026-03-03T12:54:49Z source_updated_at=2026-03-14T15:09:59Z freshness=stale]

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CONFIDENTIAL LEGAL
MEMORANDUM

TO: General Counsel and Board of Directors, CrowdStrike Holdings, Inc.

FROM: Outside Litigation Counsel

DATE: November 14, 2025

RE: Updated Analysis of Litigation and Regulatory Exposure Arising from July 2024 Outage

Prepared by: Outside Litigation Counsel

Distribution: General Counsel, Board of Directors, Executive Leadership Team;

I. EXECUTIVE SUMMARY

All legal strategies must now be oriented toward defeating the gross negligence claim in the Delta case. Beyond the Delta litigation, the Company faces manageable but significant exposure from:

● Consolidated securities litigation (low risk)

● Potential derivative actions (low risk)

● Insurance coverage disputes (medium-high risk with significant financial impact)

● Federal regulatory investigations by DOJ, SEC, and FTC (low-moderate risk, but escalating)

● Potential Fortune 500 copycat litigation (moderate-high risk, contingent on Delta outcome)

Strategic Priority: The Company should strongly consider early resolution of the Delta litigation, particularly through settlement, to significantly reduce overall exposure and provide certainty for stakeholders, customers, and investors. A favorable settlement would preempt copycat litigation and allow the Company to move forward with enhanced protocols and restored customer confidence.

The Del Rio dismissal provides critical protection against indirect consumer claims, allowing the Company to focus resources on primary threats. Absent a finding of gross negligence or willful misconduct, CrowdStrike's corrective measures, contractual protections, and cooperative regulatory posture position the company to resolve all matters without catastrophic financial impact.

This memorandum consolidates our analysis of legal exposure arising from the July 19, 2024, Falcon sensor configuration update (Channel File 291) that triggered widespread, global disruptions across critical sectors, including airlines,

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healthcare, banking, and media. This analysis incorporates recent legal developments, including specific filed litigation and regulatory inquiries, to provide a current assessment of the Company's risk profile.

Overall Assessment: The Company's overall legal exposure is significant but largely contingent on a single issue: gross negligence. The Company's contractual protections are strong and should cap liability for ordinary negligence. However, a judicial finding that the Company's conduct amounted to gross negligence would dramatically expand exposure, potentially leading to uncapped damages, voiding insurance coverage, and inviting further regulatory penalties. All legal strategy must now be oriented toward defeating this central claim.

The most significant risks relate to downstream enterprise litigation (particularly Delta Air Lines) and insurance coverage disputes. Beyond these primary threats, the Company faces consolidated securities litigation, potential shareholder derivative actions, and escalating federal regulatory inquiries. CrowdStrike's corrective measures and contractual protections position the company favorably to resolve matters without material financial impact, provided gross negligence allegations do not succeed.

II. INCIDENT OVERVIEW AND TIMELINE

July 19, 2024, 04:09 UTC – CrowdStrike released a configuration update (Channel File 291) for its Falcon Sensor software on Windows systems, triggering widespread crashes (BSODs) and boot loops.

July 19–20, 2024 – A fix was developed and deployed; recovery efforts began but restoration took several days for many organizations.

July 20, 2024 – The U.S. Cybersecurity and Infrastructure Security Agency (CISA) issued a public alert regarding the widespread outage.

July 21–25, 2024 – Airlines, hospitals, banks, and retailers worked to restore systems and operations across affected regions.

July 26, 2024 – CrowdStrike CEO reported that 97% of affected Windows sensors were back online.

Affected Parties and Financial Impact

Approximately8.5 million Windows devices were affected globally across multiple sectors:

● Airlines and airports – Major carriers including Delta Air Lines experienced mass cancellations and delays

● Healthcare – Hospitals and clinics faced interruptions in electronic medical records and scheduling systems

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● Banking and finance – Financial institutions experienced downtime in trading and payment systems

● Media and broadcasting – News networks reported outages in production and transmission systems

● Retail and hospitality – Point-of-sale and reservation systems went offline

Estimated Financial Impact:

● U.S. Fortune 500 companies (excluding Microsoft): approximately $5.4 billion in direct losses

● Insured losses: projected between $540 million and $1.08 billion

● Delta Air Lines alone: losses exceeding $500 million

III. CUSTOMER AND COMMERCIAL CLAIMS

The most significant and immediate legal exposure stems from claims by enterprise customers who suffered direct operational and financial losses.

A.  Delta Air Lines v. CrowdStrike, Inc. — PRIMARY THREAT

Filed: October 25, 2024

Court: Fulton County Superior Court, Georgia

Case No.: 24CV013621

Status: Ongoing – Motion to dismiss largely denied (May 2025)

Nature: Delta alleges breach of contract, gross negligence, computer trespass, and fraud related to widespread flight cancellations and operational losses. Delta seeks substantial damages tied to grounded flights and passenger impacts exceeding $500 million.

Critical Development - May 2025:

Judge Kelly Ellerbe largely denied the Company's motion to dismiss, allowing Delta's claims for gross negligence, breach of contract, and fraud to proceed. This ruling is significant because it threatens to bypass the contractual limitation of liability, which is the Company's primary defense. Delta has pleaded that the Company's "secret" and inadequate testing regime constituted gross negligence.

Procedural History:

● August 2024: Delta served Rule 11 safe-harbor letter disputing public statements; resolved informally

● May 2025: Motion to dismiss largely denied

● Court found Delta adequately pleaded a "secret" testing regime and cited CrowdStrike's own admission that the update was "horribly wrong"

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Risk Level: HIGH – This is the most significant active litigation with potential for material financial impact. This case represents the single greatest threat to bypassing contractual liability caps.

Key Issues:

● Whether deployment constituted gross negligence (which would void contractual liability caps)

● Application of MSA Section 10 liability cap (~$4.5M, 12 months' subscription fees)

● Application of MSA Section 8 exclusions for consequential and indirect damages

● Delta's unconscionability challenge to limitation of liability provisions

If Gross Negligence Is Established:

● Contractual liability caps would be void → exposure potentially unlimited

● Potential for punitive damages

● Insurance coverage may be denied under willful misconduct exclusions

● Would invite wave of copycat litigation from other Fortune 500 companies

- Regulatory penalties could significantly increase

Defense Strategy:

● The Company's full litigation resources must be focused on defeating the gross negligence claim in the Delta case

● Emphasize automated (not manually negligent) deployment

● Demonstrate QA protocols aligned with industry standards

● Assert that testing protocols did not fall "so far below the industry standard of care as to constitute gross negligence"

● No regulator has alleged gross negligence or willful misconduct

● Maintain transparent ESI protocol; independent audit completed by outside counsel (May 2025)

Strategic Considerations:

● This adverse ruling may encourage other heavily impacted Fortune 500 clients, particularly in the aviation and healthcare sectors, to file similar suits

● Major enterprise clients are closely watching this case; outcome will directly impact future renewal negotiations and the Company's competitive position

● Early settlement may be strategically necessary to prevent wave of copycat filings and restore investor confidence

B. Contract-Based Claims (Other Enterprise Customers)

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Nature: Breach of contract, breach of express or implied warranties, claims for indemnification, and failure to meet service-level agreements (SLAs) based on service interruption.

Contractual Defenses:

● Section 10 (Limitation of Liability) in the MSA caps recovery to 12 months' subscription fees (~$4.5M per customer)

● Section 8 (Warranties and Remedies) excludes consequential and indirect damages (e.g., business interruption losses), covering only service credits

● Force majeure clauses may apply to unforeseeable technical failures

Risk Level: Moderate – Contractual caps are strong but may be challenged under unconscionability or failure-of-essential-purpose theories, particularly if gross negligence is established in the Delta case.

Mitigation:

● Consistent reliance on MSA limitation language

● Early engagement and commercial accommodations (credits, renewals)

● Ongoing customer relationship management to prevent escalation to litigation

● Approve customer communications framework emphasizing new QA protocols and deployment safety

C. Negligence Legal Theory

Standard Negligence Claims:

Legal Elements:

● Duty: Whether a cybersecurity vendor owes an enhanced duty of care due to the critical nature of its services

● Breach: Whether the defective update represents a breach of that duty

● Causation: Direct link between the update and widespread economic harm

● Damages: Quantifiable losses resulting from the outage

Risk Level: Low – Deployment was automated, not manually negligent; QA protocols aligned with industry standards

Defense:

● Demonstrate adherence to industry best practices and standards

● Emphasize that outage was an unforeseeable technical anomaly

● Show deployment followed established protocols

● Document robust QA processes and testing procedures

● Rely on contractual liability caps and economic loss doctrine

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Economic Loss Doctrine Defense:

Recovery by plaintiffs may be limited by the economic loss doctrine, which restricts tort recovery for purely financial losses absent physical harm or a special relationship. CrowdStrike's software update did not result in physical damage but rather caused temporary system inoperability. However, this defense can be overcome if gross negligence is established.

D.  Del Rio et al. v. CrowdStrike, Inc. — DISMISSED (Critical
Victory)

Filed: August 5, 2024 Court: U.S. District Court, Western District of Texas (Austin Division) Case No.:1:24-cv-00881 Status: DISMISSED (June 19, 2025)

Nature: Putative consumer class action brought by airline passengers alleging negligence and related claims arising from flight cancellations and travel disruption.

Outcome: The Company secured a critical victory. The court held claims were preempted by the Airline Deregulation Act because harms arose from airline operations rather than direct misconduct by CrowdStrike.

Strategic Impact: This precedent should effectively bar future consumer-passenger lawsuits and provide a strong preemption defense against indirect, "downstream" claims. This allows the Company to focus resources on primary commercial and regulatory threats rather than defending against derivative consumer claims.

IV. POTENTIAL FUTURE LITIGATION

A. Fortune 500 Enterprise Customers

Risk Profile: Moderate to High

Sectors Most Likely to File:

● Aviation sector (following Delta's example if Delta succeeds)

● Healthcare sector (largest reported losses among Fortune 500)

● Banking and financial services

● Manufacturing and logistics

Anticipated Claims:

● Business interruption losses

ATTORNEY-CLIENT PRIVILEGED COMMUNICATION PREPARED IN ANTICIPATION OF
LITIGATION

6


--- PAGE 7 ---
● Breach of contract and SLA violations

● Negligence and gross negligence

- Indemnification demands

Risk Factors:

● The adverse ruling in the Delta case may encourage other heavily impacted Fortune 500 clients to file similar suits

● If Delta succeeds in establishing gross negligence, a wave of copycat litigation is highly probable

● With total estimated losses for U.S. Fortune 500 companies at approximately $5.4 billion, multiple high-value claims are conceivable

Mitigation:

● Prioritize Delta defense to prevent precedent-setting ruling

● Proactive outreach and commercial accommodations to high-value
customers

● Review indemnification scope under future MSAs to balance customer trust with liability containment

B. Small Business Class Action

Status: Pre-filing stage – We are monitoring pre-filing efforts by plaintiff-side law firms to organize a potential class action for smaller businesses impacted by business interruption

Anticipated Claims:

● Business interruption losses

● Negligence

- Breach of contract

● Breach of implied warranty of merchantability

Risk Level: Moderate – Class certification may be difficult due to:

● Varying contract terms across customers

- Individual damages calculations required

● Lack of privity for many potential class members

● Contractual arbitration clauses may compel individual proceedings

Defense Strategy:

● Challenge class certification on grounds of individual issues predominating

● Assert contractual defenses and limitations of liability

● Argue lack of standing for indirect claimants

● Leverage  Del Rio precedent where applicable

ATTORNEY-CLIENT PRIVILEGED COMMUNICATION - PREPARED IN ANTICIPATION OF
LITIGATION

7


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## Vector Search Results

### 1) Delta Litigation Case File/Case and Statutory Law/Law for Legal Research Overview Two/Fastcase v LA Writer LLC.pdf
- Page: 8
- Relevance: 0.527

```text
Case: 17-14110 Date Filed: 10/29/2018 Page: 8 of 16

copyrighted works at issue, we held that the anticipated infringement claims could not confer subject-matter jurisdiction. Id.

Since our decision in Stuart Weitzman, however, the law on § 411(a)'s registration requirement has changed. In Reed Elsevier, Inc. v. Muchnick, the Supreme Court held that while § 411(a)'s registration requirement remains a "precondition to filing a claim," it "does not restrict a federal court's subject-matter jurisdiction." 559 U.S. 154, 157, 130 S. Ct. 1237, 1241 (2010). Thus, while a complaint claiming infringement of an unregistered copyright can be dismissed for failure to state a claim, it cannot be dismissed for lack of jurisdiction.

To be sure, the facts of Muchnick and this case are substantially different. As the District Court noted, the decision in Muchnick was made in the context of a class action certification for the purposes of settlement approval, not in the context of a declaratory judgment. But the District Court did not explain why this distinction mattered or why we should decline to extend Muchnick beyond Muchnick-like facts. Indeed, this Court has already explained—in an appeal from dismissal of a copyright infringement action, a factual setting very different from Muchnick—that § 411(a) is no longer a jurisdictional bar. Fourth Estate Pub. Benefit Corp. v. Wall-Street.com, LLC, 856 F.3d 1338, 1339–40 (11th Cir. 2017), cert. granted, 138 S. Ct. 2707 (mem.). See also Roberts v. Gordy, 877 F.3d 1024,
```

### 2) Delta Litigation Case File/Case and Statutory Law/Law for Legal Research Overview Two/Community State Bank v Strong.pdf
- Page: 37
- Relevance: 0.508

```text
11/13/25, 6:38 PM
COMMUNITY STATE BANK v. STRONG (2007) | FindLaw

Health Sys. , Inc. , 441 F. 3d 1306, 1308 (11th Cir. 2006) (res judicata); Agripost, Inc. v. Miami-Dade County, ex rel. Manager, 195 F. 3d 1225, 1229 n. 7 (11th Cir. 1999) (collateral estoppel). Under Georgia law, for a claim to be barred under the doctrine of res judicata, the following elements must be met: "(1) identity of the cause of action, (2) identity of the parties or their privies, and (3) previous adjudication on the merits by a court of competent jurisdiction. " Karan, Inc. v. Auto-Owners Ins. Co. , 280 Ga. 545, 629 S. E. 2d 260, 262 (2006). The doctrine of collateral estoppel "precludes the re-adjudication of an issue that has previously been litigated and adjudicated on the merits in another action between the same parties or their privies. " Id. at 262. Even assuming that the state court's sanction of striking portions of the payday defendants' pleading operates as an adjudication on the merits for purposes of preclusion, see, e. g. , Brantley v. Sparks, 167 Ga. App. 323, 306 S. E. 2d 337, 338 (1983) (sanction of dismissal after finding of willful violation of discovery order operates as an adjudication on the merits), a further requirement of both res judicata and collateral estoppel under Georgia law is that the prior adjudication be final. "It is the general rule that a judgment sought to be used as a basis for the application of the doctrine of res judicata (or collateral estoppel) must be a final judgment. In Georgia a judgment is suspended when an appeal is entered within the time allowed. And the judgment is not final as long as there is a right to appellate review. " CS-Lakeview At Gwinnett, Inc. v. Retail Dev. Partners, 268 Ga. App. 480, 602 S. E. 2d 140, 142 (2004) (quoting Greene v. Transport Ins. Co. , 169 Ga. App. 504, 313 S. E.
```

### 3) Delta Litigation Case File/Case and Statutory Law/Law for Legal Research Overview Two/Rule 12.pdf
- Page: 6
- Relevance: 0.503

```text
686; *Boro Hall Corp. v. General Motors Corp.* (C.C.A.2d, 1942) 124 F.(2d) 822, cert. den. (1943) 317 U.S. 695. See also *Kithcart v. Metropolitan Life Ins. Co.* (C.C.A.8th, 1945) 150 F.(2d) 997, aff'g 62 F.Supp. 93.

It has also been suggested that this practice could be justified on the ground that the federal rules permit "speaking" motions. The Committee entertains the view that on motion under Rule 12(b)(6) to dismiss for failure of the complaint to state a good claim, the trial court should have authority to permit the introduction of extraneous matter, such as may be offered on a motion for summary judgment, and if it does not exclude such matter the motion should then be treated as a motion for summary judgment and disposed of in the manner and on the conditions stated in Rule 56 relating to summary judgments, and, of course, in such a

https://www.law.cornell.edu/rules/frcp/rule_12
6/15
```

### 4) Delta Litigation Case File/Case and Statutory Law/Law for Legal Research Overview Two/Community State Bank v Strong.pdf
- Page: 11
- Relevance: 0.489

```text
; Assocs., Inc. v. Henderson, Few & Co., 774 F.2d 441, 443 (11th Cir.1985) (affirming district court's denial of leave to amend on other grounds).¹⁹ As we explained, the plaintiff's "choice of a state court forum was defeated by the removal. Once [the plaintiff] found itself in federal court, it may well have decided a different litigation strategy was in order." Id.

Kidder, Peabody & Company, Inc. v. Maxus Energy Corp., 925 F.2d 556 (2d Cir.1991), which we discussed at some length and with approval in Household Bank, see 320 F.3d at 1259-60, presented a fact pattern similar to the one we confront in this case. There, the declaratory judgment defendant, Maxus, had threatened to bring various claims, including one federal claim, against the plaintiff, Kidder. However, Maxus then filed an action in state court bringing only state-law claims. 925 F.2d at 559, 562. Two hours later, Kidder filed a declaratory judgment action in federal district court, alleging federal question jurisdiction on the ground that Maxus could bring a federal claim against it. Id. at 559. Maxus moved to dismiss for lack of subject matter jurisdiction and mootness, representing to the district court that it would never bring any such federal claim against Kidder. Id. at 560, 562-63. The Second Circuit rejected that argument:

A controversy ceases to be "real and immediate" when "the issues presented are no longer 'live' or when the parties lack a legally cognizable interest in the outcome." Powell v. McCormack, 395 U.S. 486, 496, 89 S.Ct. 1944, 23 L.Ed.2d 491 (1969). This is not a case where the parties have entered into a settlement, or where the defendant has entered into a binding, judicially enforceable agreement. In those situations, the claims inarguably were moot. By contrast, Maxus attempts to unilaterally bar Kidder's claims for declaratory relief simply by representing that it will not bring an action under the federal securities laws.
```

### 5) Delta Litigation Case File/Case and Statutory Law/Law for Legal Research Overview Two/Multi financial securities v Rua.pdf
- Page: 7
- Relevance: 0.486

```text
11/13/25, 6:38 PM
Multi-financial Securities Corp. (f.k.a. Ifg Network Securities, Inc.), Plaintiff-appellant, v. Rua L. King, Defendant-appellee, 386 F.3d...

08 (M.D. Fla .2002). The reasoning of these decisions is not persuasive, however, because they read a limitation into the Code that is absent from its language. The NASD, moreover, has been on notice at least since 2001—when the Second Circuit issued John Hancock—of the broad meaning the courts would attribute to the language used. The NASD could have prevented any purported "significant injustice" merely by including simple limiting language, as it did with Rules 2270(b) and 2520(a) (3). The NASD has not done so, and this Court only can conclude that the John Hancock interpretation is consistent with the NASD members' reasonable expectations. Finally, the Code's second requirement, that the dispute arise in connection with the business of the member, provides for the general connection between the customer's dispute and the member's conduct that these decisions impose upon the customer-member requirement.
```

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--- PAGE 1 ---
                                         Short Memo
                         Plymouth Class Posture and Stone Suit
To: General Counsel
From: Raycaster Docs
Date: March 20, 2026
Re: Whether the Plymouth matter can support dismissal of Stone’s suit
Issue: Whether the Plymouth securities class action, which is still pending certification and does
not show a related opt-out process, is likely to support a successful motion to dismiss Larry
Stone’s suit.
Short Answer: Probably not. The current Plymouth posture is a weak dismissal ground
because no class has been certified yet, and no opt-out rights have been triggered. Under Rule
23(c)(2) and (c)(3), notice and exclusion apply only to a certified Rule 23(b)(3) class, and only a
certified class judgment binds non-excluded members. The Plymouth complaint seeks
certification, and the internal memo states that class certification is still pending.
Analysis: Stone appears to be within the proposed class period because the stock ledger
reflects a Larry Stone purchase on April 3, 2024. That makes him, at most, a putative class
member for now—not a bound class member. Because there is no certified class and no final
judgment, Plymouth does not supply res judicata or claim-preclusion grounds for dismissal. The
better procedural response, if the pleadings materially overlap, would be consolidation or a stay,
not dismissal based solely on the Plymouth action.
Bottom Line: The Plymouth matter is unlikely to support a successful motion to dismiss Stone’s
suit on class-action grounds alone. Any dismissal would need to rest on Stone-specific pleading
defects or other independent defenses, not on the fact that Plymouth is pending as an
uncertified class action.
Sources reviewed: Plymouth County Retirement Association CrowdStrike Class-Action
Complaint (pp. 2, 24-25, 27); CrowdStrike GC Memo (v1) (p. 1); Fed. R. Civ. P. 23 (pp. 63-66);
CrowdStrike stock transactions workbook (Larry Stone entry on 4/3/2024).
Note: This memo is limited to the Plymouth-class issue and does not assess Stone-specific
PSLRA pleading defects.


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