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Declaration of Frank C. Torchio for Settlement Purposes

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Case 2:07-cv-05295-MRP -MAN Document 987-4 Filed 10/11/10 Page 15 <strong>of</strong> 721 Page ID<br />

#:39203<br />

which cannot be explained by the return on the market) is attributed to new company-specific<br />

in<strong>for</strong>mation. If the disclosure <strong>of</strong> company-specific in<strong>for</strong>mation is accompanied by a security<br />

return that is outside <strong>of</strong> the security’s normal volatility range (as measured by the market model),<br />

then the return is said to be “statistically significant.” The measure <strong>of</strong> statistical significance<br />

allows the researcher to assess the probability that a security-price movement was due to new<br />

in<strong>for</strong>mation disclosed on a particular date and not due to chance.<br />

23. Event studies are most useful in determining the effects <strong>of</strong> new in<strong>for</strong>mation on<br />

security prices when: (i) there is a well-defined public disclosure or announcement; (ii) the time<br />

that the news item reaches the market is known; (iii) there is no reason to believe that the market<br />

anticipated the news item; and (iv) it is possible to isolate the effect <strong>of</strong> the news item from<br />

market, industry, and other issuer-specific factors simultaneously affecting the issuer’s security<br />

price. 15<br />

B. Identifying Relevant Disclosures<br />

24. There are four key considerations <strong>for</strong> an economic analyst when identifying<br />

which disclosures are corrective <strong>of</strong> an alleged securities fraud.<br />

15 David I. Tabak and Frederick C. Dunbar, “Materiality and Magnitude: Event Studies in<br />

the Courtroom,” in Litigation Services Handbook: The Role <strong>of</strong> the Financial Expert, Third<br />

Edition, ed. by Roman L. Weil, Michael J. Wagner and Peter B. <strong>Frank</strong>, Wiley, 2001, 19.2.<br />

11

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