Perez v. Target Corporation

U.S. District Court, District of Minnesota

Perez v. Target Corporation

Trial Court Opinion

            UNITED STATES DISTRICT COURT                             
                DISTRICT OF MINNESOTA                                


Rafael E. Perez, individually and on   Case No. 23-CV-00769 (JMB/TNL)     
behalf of all others similarly situated, and                              
Terry and Diane Van Der Tuuk Living Trust,                                

          Plaintiffs,                                                

    v.                                                                         ORDER 

Target Corporation, Brian C. Cornell,                                     
Michael J. Fiddelke, A. Christina                                         
Hennington, and John J. Mulligan,                                         

          Defendants.                                                


Garrett D. Blanchfield, Jr., and Roberta A. Yard, Reinhardt Wendorf & Blanchfield, 
Minneapolis, MN; Carl Malmstrom (pro hac vice), Wolf Haldenstein Adler Freeman & 
Herz LLC, Chicago, IL; Shannon L. Hopkins (pro hac vice), Levi & Korsinsky, LLP, New 
York, NY; and Gregory M. Potrepka (pro hac vice), Levi & Korsinsky, LLP, Stamford, 
CT, for Lead Plaintiff Terry and Diane Van Der Tuuk Living Trust.         
Garrett D. Blanchfield, Jr., and Roberta A. Yard, Reinhardt Wendorf & Blanchfield, 
Minneapolis, MN, for Plaintiff Rafael E. Perez.                           
Jeffrey  P.  Justman,  Faegre  Drinker  Biddle  &  Reath  LLP,  Minneapolis,  MN;  Sandra 
Grannum (pro hac vice), Faegre Drinker Biddle & Reath LLP, Florham Park, NJ; and 
Alexander J. Rodney (pro hac vice), Sandra Goldstein (pro hac vice), and Stefan H. 
Atkinson (pro hac vice), Kirkland & Ellis LLP, New York, NY, for Defendants Target 
Corporation, Brian C. Cornell, Michael J. Fiddelke, A. Christina Hennington, and John J. 
Mulligan.                                                                 


This matter is before the Court on Defendants Target Corporation’s (Target), Brian 
C. Cornell’s, Michael J. Fiddelke’s, A. Christina Hennington’s, and John J. Mulligan’s 
(together, Defendants) motion to dismiss (Doc. No. 81) Lead Plaintiff Terry and Diane Van 
Der Tuuk Living Trust’s (the Trust) Amended Complaint, which alleges violations of 
sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the Exchange Act), 
15 U.S.C. §§ 78j(b) and 78t(a), and the Securities and Exchange Commission’s (SEC) 

implementing regulation, Rule 10b-5, 
17 C.F.R. § 240
.10b-5, on behalf of itself and all 
persons who purchased or otherwise acquired Target common stock between November 
17, 2021 and May 17, 2022 (the Class Period).  For the reasons explained below, the Court 
grants Defendants’ motion in its entirety.                                
                    BACKGROUND1                                      

I.   THE PARTIES                                                          
Target is a national retailer.  (Doc. No. 70 [hereinafter, “Am. Compl.”] ¶ 29.)  Its 
common stock trades on the New York Stock Exchange.  (Id. ¶ 17.)  Defendants Cornell, 
Fiddelke, Hennington, and Mulligan (together, Individual Defendants) were executive 
officers of Target during the Class Period.2  (Id. ¶¶ 18–21.)             
Plaintiffs purchased Target common stock during the Class Period.  (Id. ¶¶ 14, 163.)  

As described more fully below, Plaintiffs allege that the Defendants made materially false 
and misleading statements to investors during the Class Period while in possession of 
material, non-public adverse information about Target that they purposefully concealed 


1 The following facts are drawn from the Amended Complaint, as well as “documents 
incorporated into the complaint by reference, and matters” subject to judicial notice, such 
as public SEC filings, stock price history, and industry trends.  Tellabs, Inc. v. Makor Issues 
& Rts., Ltd., 
551 U.S. 308, 322
 (2007).                                   

2 Cornell was Target’s Chief Executive Officer and Board Chairman.  (Id. ¶ 18.)  Fiddelke 
was Target’s Executive Vice President (EVP) and Chief Financial Officer.  (Id. ¶ 19.)  
Hennington was Target’s EVP and Chief Growth Officer.  (Id. ¶ 20.)  Mulligan was 
Target’s EVP and Chief Operating Officer.  (Id. ¶ 21.)                    
from investors.  (Id. ¶ 24.)  Plaintiffs further allege that Fiddelke, Cornell, and Hennington 
had a motive to mislead investors because they executed suspicious stock sales during the 

Class  Period  while  in  possession  of  material,  non-public  information  about  Target’s 
inventory overstock that was not disclosed to investors and while Target’s common stock 
price  was  artificially  inflated  due  to  Defendants’  materially  false  and  misleading 
statements.  (Id. ¶¶ 144–49.)                                             
II.  ALLEGATIONS OF DECLINING DEMAND                                      
In  2020,  when  some  businesses  were  forced  to  close  due  to  the  COVID-19 

pandemic, Target was permitted to remain open as an essential business.  (Id. ¶ 2.)  During 
that year, Target reported record sales growth across each of its five “core” product 
categories: (1) apparel and accessories; (2) beauty and household essentials; (3) food and 
beverage; (4) hardlines; and (5) home furnishings and décor.  (Id. ¶¶ 29–30.)  As consumers 
spent more time at home due to lockdowns, Target’s sales in the hardlines and home goods 

(HHG)3 categories particularly grew, each constituting roughly one fifth of Target’s sales 
going into fiscal year 2021.  (Id. ¶¶ 2, 29.)  Despite this growth, in late 2020, supply chain 
issues prevented Target from keeping its shelves fully stocked, which negatively impacted 
its revenue.  (Id. ¶ 3.)                                                  
By early- to mid-2021, when COVID restrictions were lifting and non-essential 

businesses reopening, Plaintiffs allege that consumers’ shopping habits shifted away from 

3 The hardlines category includes electronics, toys, entertainment, sporting goods, and 
luggage.  (Id. ¶ 29.)  The home goods category includes furniture, lighting, storage, 
kitchenware, small appliances, home décor, bed and bath, home improvement, school and 
office supplies, greeting cards, party supplies, and seasonal merchandise.  (Id.)       
HHGs, causing the availability of those products to increase.  (Id.)  Despite this shift in 
consumer preferences, Plaintiffs allege that by at least June 2021, Target had begun 

preordering large quantities of HHGs to ensure its shelves were stocked going into the 2021 
holiday season.  (Id. ¶¶ 4–5.)  Plaintiffs allege that Target procured this inventory without 
regard  for  consumer  preferences,  which  resulted  in  Target’s  warehouses,  distribution 
centers, and stores becoming overstocked with HHGs by September of 2021.  (Id. ¶ 6.)   
Plaintiffs also allege that during the Class Period, Defendants misled investors by 
making a series of twenty statements.  (Id. ¶¶ 80–115.)  Plaintiffs allege that the twenty 

statements  were  materially  false  and  misleading  for  essentially  the  same  reason: 
Defendants were concealing the fact that Target had “abandoned its customer-focused 
purchasing strategy” in favor of “indiscriminately buying large quantities of inventory” 
that consumers did not want, particularly HHGs.  (Id. ¶ 39.)  Plaintiffs base this allegation 
on statements imputed to three confidential witnesses (CWs)—former Target employees 

who claim to have observed HHG inventory becoming overstocked in the months leading 
up to and through the Class Period.4  (Id. ¶¶ 80–115.)                    
CW-1 was a warehouse associate at Target’s regional distribution center (RDC) in 
Albany, Oregon, which services five states in the Pacific Northwest, during the Class 
Period.  (Id. ¶ 26.)  In that role, CW-1 was responsible for unloading and sorting inventory 


4 Plaintiffs also ask the Court to consider “anonymous employee posts on multiple Internet 
forums for Target employees from across the country” that they argue “corroborate the CW 
accounts.”  (Doc. No. 91 at 29; Am. Compl. ¶¶ 74–78.)  Defendants contend that the Court 
should not consider these posts because “anonymous and unsubstantiated user comments 
badly flunk pleading fraud.”  (Doc. No. 83 at 23 n.10.)  The Court declines to consider 
these posts, but even if it did, they would not have a determinative effect on the outcome. 
received from vendors, selecting inventory to ship to stores, and attending daily shift 
meetings to discuss  the state of inventory  and how it exceeded  the RDC’s intended 
capacity.5  (Id. ¶¶ 46–47, 49–50.)  CW-1 observed inventory levels at the RDC, including 

“stash aisles” of excess inventory and 50 to 100 trailers of inventory in the RDC parking 
lot, and learned through daily meetings with the Senior Director of Distribution (and 
headquarters liaison) of the RDC’s decreasing capacity for inventory.  (Id. ¶¶ 49–54.)   
CW-2 was an operations manager at Target’s flow center warehouse in Logan 
Township, New Jersey, during the Class Period, and was responsible for replenishing 

inventories and fulfilling e-commerce orders for much of the East Coast, including direct-
to-consumer online sales and stores in five states.  (Id. ¶ 56.)  CW-2 observed inventory 
accumulating at the warehouse.  (Id. ¶¶ 58–60.)  CW-2 was also given inventory reports 
from Target headquarters generated from a custom-built warehouse management system.  
(Id. ¶ 61.)                                                               

CW-3 was an executive team lead (ETL) at a major Target store in New York during 
the Class Period, and was responsible for receiving and unloading incoming inventory, 
managing  the  back  stockroom,  getting  inventory  onto  the  sales  floor,  and  fulfilling 
customer orders.  (Id. ¶ 64.)  CW-3 had access to Target’s inventory management data 
system and received directives from headquarters based on data from that system.  (Id. 

¶¶ 67–69.)  CW-3 also communicated directly with ETLs who oversaw other stores in the 


5 “According to CW-1, the overwhelming majority of inventory sold in Target stores flows 
from vendors through Target’s RDCs, save for ‘very few’ products that go straight to 
stores.”  (Am. Compl. ¶ 47.)                                              
same region, as well as the district store director, who visited stores weekly or bi-weekly 
and observed and discussed overstock on the sales floor and in the stockroom with ETLs.  

(Id. ¶ 70.)                                                               
III.  ALLEGATIONS OF FALSE AND MISLEADING STATEMENTS                      
Based on information provided by the CWs, Plaintiffs allege that the following 
twenty statements, made by Defendants across five separate dates during the Class Period, 
were materially false and misleading.                                     

A.   November 17, 2021 Statements                                    
On November 17, 2021, Target held a Q3 2021 earnings call in which it announced 
its third quarter financial results.  (Id. ¶ 80.)  During that call, Hennington claimed that 
Target was using consumer insights to inform its inventory purchasing decisions:  
     We continuously evaluate our guests’ mindset, which serves      
     as a North Star for all our strategies and decisions.  We       
     remain  laser-focused  on  their  experiences  with  us  and    
     expectations of us.  And we strive to build flexibility and     
     agility into our plans to ensure we show up at our best for them 
     during the holidays and all year round.                         

                          ***                                        

     As  [Mulligan]  will  outline  in  more  detail,  our  teams  are 
     working diligently to get the right inventory to the right place 
     at the right time.  Doing so has driven some near-term gross    
     margin  pressure,  appropriate  long-term  investment  in  the  
     relationship  with  our  guests.    Bottom  line,  based  on  the 
     incredible  efforts  of  our  team,  we  feel  good  about  our 
     inventory levels heading into the holiday season.               
(Id. ¶ 81 (Statements 1, 2, and 3) (emphasis in original).)6  On that same call, Mulligan told 
investors that Target was focused on moving appropriate levels of inventory, particularly 

during the prime holiday shopping season, and stated: “On our supply chain team, the focus 
is on moving the right amount of inventory to the right place at the right time.  (Id. ¶ 82 
(Statement 4) (emphasis in original).)  Later during that call, Mulligan reiterated that, 
“while we continue to see some periodic outages across different items and categories, 
we’re entering the holidays with a very healthy inventory position overall.  (Id. ¶ 84 
(Statement 5) (emphasis in original).)                                    

Following Defendants’ prepared statements, the earnings call turned to a question-
and-answer session with securities analysts.  (Id. ¶ 86.)  In response to a question posed 
about how inventory levels were affecting Target’s gross margin, Fiddelke emphasized that 
Target purchased and positioned its inventory with reference to guests’ expectations:  
     As you know, we don’t guide margins specifically out into       
     future quarters.  But I will say and reiterate what I said in my 
     remarks.  I think you’re seeing in the third quarter, the result 
     of some very specific investments we made.  And the biggest     
     of those investments is an investment to make sure we’ve got    
     a great inventory position heading into the fourth quarter.     
     And pulling all the levers within the system to ensure we’re    
     there for the guest has been our priority.  And some of those   
     levers, think of expediting product to come at a cost, and you  
     saw some of that in the third quarter.                          

     But I feel really good about the payoff from an investment      
     decision like that.  We’ve got inventory of $2 billion north of 
     last year, up almost 20% on a year-over-year basis.  And        
     that’s fueling the continued top line growth that we see.  So,  
     I feel really good about the set of investments that we’re      

6 All italicized and bolded text are statements that Plaintiffs allege are false and misleading.  
(Am. Compl. at 28 n.8.)  Additional statements are provided for necessary context.  (Id.)   
     making and how they have us positioned for the back part of     
     the year.                                                       

(Id. ¶ 86 (Statement 6) (emphasis in original).)                          
Plaintiffs allege that the November 17, 2021 statements were materially false and 
misleading because by at least June 2021, Target was not taking customers’ shifting buying 
habits into account but, instead, preordered excess quantities of HHG inventory, which 
resulted in a massive overstock that was not “well-positioned” or “healthy” but that would 
need to be marked down and discounted in order to sell.  (Id. ¶¶ 83, 85, 87.)       
B.   November 24, 2021 Statements                                    
On November 24, 2021, Target filed a Q3 2021 Form 10-Q, which reported its 
financial and operating results for that quarter.  (Id. ¶ 88.)  The Form 10-Q indicated that 

its inventory management aimed to offset supply chain pressures:          
     Since  the  onset  of  the  COVID-19  pandemic,  we  have       
     experienced strong comparable sales growth and significant      
     volatility in our sales category and channel mix, including     
     same-day  fulfillment  options.    Note  4  presents  sales  by 
     category.    We  have  taken  various  actions,  including      
     accelerating purchases of certain merchandise in our core       
     categories and, early in the pandemic, slowing or canceling     
     purchase orders, primarily for Apparel and Accessories.  As a   
     result, during the quarter ended May 2, 2020, we recorded $216  
     million of purchase order cancellation fees in Cost of Sales.   

(Id. (Statement 7) (emphasis in original).)  It also stated that Target’s inventory position 
was a positive driver of the gross margin rate in contrast to negative drivers (e.g., supply 
chain issues), as follows:                                                
     For the three months ended October 30, 2021, our gross margin   
     rate  was  28.0  percent  compared  with  30.6  percent  in  the 
     comparable prior-year period.  This decrease reflected the net  
     impact of[:]                                                    
     •  pressure  from  higher  merchandise  and  freight  costs  and 
     higher  inventory  shrink,  partially  offset  by  the  benefit  of 
     historically low promotional and clearance markdown rates;      
     • supply chain pressure related to increased compensation and   
     headcount in our distribution centers; and                      
     • favorable mix in the relative growth rates of higher and lower 
     margin categories.                                              
(Id. ¶ 90 (Statement 8) (emphasis in original).)                          
The Form 10-Q also informed investors that Target had factored customer sales 
trends in its inventory position, as follows:                             
     Inventory was $15.0 billion as of October 30, 2021, compared    
     with $10.7 billion and $12.7 billion at January 30, 2021, and   
     October 31, 2020, respectively.  The increase over the balance  
     as of October 31, 2020, reflects efforts to align inventory with 
     sales trends.                                                   

(Id. ¶ 92 (Statement 9) (emphasis in original).)  Finally, the Form 10-Q incorporated by 
reference statements in Target’s Form 10-K, which it filed with the SEC on March 10, 
2021, that were purportedly made to warn investors of certain risk factors, as follows: 
     If we do not anticipate and respond quickly to changing         
     consumer  preferences,  our  sales  and  profitability  could   
     suffer.  A large part of our business is dependent on our       
     ability to make trend-right decisions and effectively manage    
     our inventory in a broad range of merchandise categories,       
     including apparel, accessories, home décor, electronics, toys,  
     seasonal offerings, food, and others.  If we do not obtain      
     accurate and relevant data on guest preferences, predict and    
     quickly respond to changing consumer tastes, preferences,       
     spending patterns and other lifestyle decisions, emphasize the  
     correct  categories,  implement  competitive  and  effective    
     pricing  and  promotion  strategies,  or  personalize  our      
     offerings  to  our  guests,  we  may  experience  lost  sales,  
     spoilage, and increased inventory markdowns, which could        
     adversely affect our results of operations.                     

(Id. ¶ 94 (Statement 10) (emphasis in original).)                         
Plaintiffs allege that the November 24, 2021 statements were materially false and 
misleading because the purported risk being warned of had already materialized and 
because Defendants failed to disclose that, in preordering massive quantities of hardline 
and home good inventory, Target had abandoned the use of customer data and insights, 
which was creating an immense overstock of those items, which would eventually need to 
be marked down and discounted.  (Id. ¶¶ 89, 91, 93, 95.)                  
C.   March 1, 2022 Statements                                        
On March 1, 2022, Target announced its 2021 Q4 earnings.  (Id. ¶ 96.)  A press 

release stated that Target’s “[f]ull-year gross margin rate was 28.3 percent, in line with 
28.4 percent in 2020, reflecting pressure from increased supply chain, merchandise, and 
freight costs largely offset by favorable category mix and lower markdowns.”  (Id. 
(Statement 11) (emphasis in original).)                                   
On a Q4 earnings call, Hennington emphasized that Target’s business model, which 

factored in customer preferences, gave the company a unique competitive edge, as follows:  
     We have created momentum through unique and innovative          
     strategies, many of which began long before the onset of the    
     pandemic.  And because of our durable, flexible business        
     model, we have proven we can adapt to any environment.          
     We’ll continue to play offense and accelerate these strategies  
     while listening to the ever-changing wants and needs of our     
     guests to ensure our playbook is a direct reflection of what they 
     have come to expect from Target.                                
(Id. ¶ 98 (Statement 12) (emphasis in original).)  On that same call, Fiddelke discussed 
Target’s plans for markdowns in the coming year, stating, “[W]e’re planning for a small 

increase in markdown rates in 2022 as we move past the dramatically low rates we’ve 
seen over the last couple of years.”  (Id. ¶ 100 (Statement 13) (emphasis in original).)   
Following Defendants’ prepared statements, the call opened up to a question-and-
answer format with securities analysts.  (Id. ¶ 101.)  In response to an analyst question 
about Target’s efficiency in markdowns, Fiddelke said the following:      

     The shape of profit for the year will be like we described,     
     where you could expect it to build over the course of the year.  
     When  it  comes  to  markdowns  specifically,  there’s  some    
     markdowns that we’ve been rooting for returning.  To be         
     better in stock with stronger inventory levels means a few      
     more  clearance  markdowns,  and we’re  planning  for  that     
     outcome in the upcoming year.                                   

(Id. (Statement 14) (emphasis in original).)  When analysts on the call continued to inquire 
about Target stores’ capacity to store inventory, Mulligan said the following: 
     I think the other thing I’d add on is as inventory turns increase 
     with scale, you just push things through faster.  Speed and flow 
     of inventory is the key to the whole game, like we were just    
     talking about with Robby.  And as that happens, we see it in    
     our largest stores, they just move inventory.  It’s constantly  
     moving through.  It shows up at night.  It’s out the store the  
     next day.  That’s capacity.  You’re just moving inventory.  So  
     a lot of headroom for growth from that perspective.             

(Id. ¶ 103 (Statement 15) (emphasis in original).)                        
That  same  day,  Fiddelke  also  took  part  in  an  interview  with  Bloomberg’s 
“Bloomberg Surveillance” television program.  (Id. ¶ 105.)  When asked about how Target 
handled supply chain disruptions and inflation, Fiddelke responded as follows:  
     Well, as you might expect, it’s a situation we monitor really   
     closely  and  I’ll  start  by  just  saying  our  hearts  go  out  to 
     everyone impacted by the situation in Ukraine.  I know it       
     weighs heavily on my mind, our Target team and our guests.      
     We’re  fortunate.    We’ve  got  the  benefit  of  a  really    
     sophisticated supply chain that’s navigated a lot of challenges 
     over the last two years.  Incredibly well.  I feel really good  
     about  our  inventory  position  today,  up  30%  to  last  year.  
     That’s a  testament to us working through some of those         
     supply chain challenges.  So, we should be well positioned to   
     start the year.                                                 

(Id. ¶ 105 (Statement 16) (emphasis in original).)                        
Plaintiffs  allege  that  the  March  1,  2022  statements  were  materially  false  and 
misleading because they failed to disclose that Target had abandoned its “durable, flexible 
business model” as it related to inventory management, “gave the false impression that 
Target was not overstocked in inventory such that the Company would not need to take 
major  markdowns  and  thereby  have  a  higher  gross  margin,”  “gave  the  misleading 
impression that at that time inventory was constantly moving and not building up and that 
Target stores had plenty of inventory capacity,” and because “Defendants had no basis to 
view Target’s inventory increase as positive or its inventory status as ‘well positioned.’”  
(Id. ¶¶ 97, 99, 102, 104, 106.)  Rather, by June 2021, Defendants had begun preordering 
large quantities of hardline and furniture inventory without regard for customer trends.  (Id. 
¶ 106.)    That  inventory  piled  up  in  Target’s  distribution  centers  and  stores  because 
consumers were not buying it and, in turn, Target would be compelled to mark that 
inventory down and write it off the following quarter.  (Id.)             
D.   March 9, 2022 Statements                                        
On March 9, 2022, Target filed a Form 10-K with the SEC, which reported its results 

for Q4 of 2021.  (Id. ¶ 107.)  It told investors the following:           
     Effective inventory management is key to our ongoing success,   
     and we use various techniques including demand forecasting      
     and planning and various forms of replenishment management.     
     We achieve effective inventory management by staying in-        
     stock in core product offerings, maintaining positive vendor    
     relationships,  and  carefully  planning  inventory  levels  for 
     seasonal and apparel items to minimize markdowns.               

(Id. ¶ 108 (Statement 17) (emphasis in original).)  It also described Target’s gross margin 
rate as “a boon,” as follows:                                             
     Our gross margin rate was 28.3 percent in  2021 and 28.4        
     percent in 2020.  This decrease reflected the net impact of[:]  
     • supply chain pressure related to increased compensation and   
     headcount in our distribution centers, partially offset by the  
     small net benefit of a higher percentage of digital sales fulfilled 
     through our lower-cost same-day fulfillment options;            
     •  higher  merchandise  and  freight  costs  partially  offset  by 
     historically low promotional and clearance markdown rates;      
     and                                                             
     • favorable mix in the relative growth rates of higher and      
     lower margin categories.                                        
(Id. ¶ 110 (Statement 18) (emphasis in original).)                        
The Form 10-K also represented that Target’s year-end 2021 inventory was up by 
$3 billion from 2020 because “[t]he increase in inventory levels reflect our efforts to align 
inventory with sales trends, and elevated in-transit inventory related to import supply chain 
delays.”  (Id. ¶ 112 (Statement 19) (emphasis in original).)  Finally, the Form 10-K 
purported to warn investors of the risk that Target’s business could be negatively impacted 
if Target failed to adapt to changing consumer buying behaviors:          

     If we do not anticipate and respond quickly to changing         
     consumer  preferences,  our  sales  and  profitability  could   
     suffer.  A large part of our business is dependent on our ability 
     to  make  trend-right  decisions  and  effectively  manage  our 
     inventory  in  a  broad  range  of  merchandise  categories,    
     including apparel, accessories, home décor, electronics, toys,  
     seasonal offerings, food and beverage, and others.  If we do not 
     obtain  accurate  and  relevant  data  on  guest  preferences,  
     predict  and  quickly  respond  to  changing  consumer          
     preferences, spending patterns, and other lifestyle decisions,  
     emphasize the correct categories, implement competitive and     
     effective pricing and promotion strategies, or personalize our  
     offerings to our guests, we may experience lost sales, spoilage, 
     and increased inventory markdowns, which could adversely        
     affect  our  results  of  operations.    During  the  COVID-19  
     pandemic, many guests significantly reduced their spending on   
     dining, travel, lodging, and other leisure activities outside their 
     homes, which may have contributed to our increased sales,       
     particularly  for  essential  items  and  merchandise  associated 
     with guests spending more time at home.  If we are unable to    
     effectively adapt if or when guests increase spending on other  
     categories, it could lead to lower sales and adversely affect   
     our results of operations.                                      

(Id. ¶ 114 (Statement 20) (emphasis in original).)                        
Plaintiffs  allege  that  the  March  9,  2022  statements  were  materially  false  and 
misleading  because  the  purported  risk  being  warned  of  had  already  materialized, 
Defendants  were  not  “carefully  planning  inventory  levels,”  “achiev[ing]  effective 
inventory management,” or “align[ing] inventory with sales trends” and did not have a 
“favorable mix.”  (Id. ¶¶ 109, 111, 113, 115.)  Rather, by at least June 2021, Defendants 
purposefully preordered large quantities of hardline and furniture inventory without regard 
for customer trends.  (Id.)  That inventory piled up in Target’s distribution centers and 
stores because consumers were not buying it and, in turn, Target had been and would be 
compelled to mark that inventory down and write it off.  (Id.)            

IV.  TARGET ANNOUNCEMENT OF DEMAND DECLINE                                
On May 18, 2022, Target announced its Q1 results.  (Id. ¶ 116.)  According to 
Plaintiffs,  that  announcement  revealed  that  Target’s  net  profits  were  down  52%,  its 
operating margin was “well below expectations, driven primarily by gross margin pressure 
reflecting actions to reduce excess inventory,” and that gross margin had dropped to 25.7% 
compared to 30.0% in the same quarter 2021, which “reflected higher markdown rates.”  

(Id.)  Hennington stated that,                                            
     as supply grew and demand shifted away from bigger, bulkier     
     products like furniture, TVs and more, we needed to make        
     difficult trade-off decisions . . . .  To preserve the quality of on-
     shelf presentations and support the guest experience, we chose  
     [to  make  room  for  fast-growing  categories],  leading  to   
     incremental markdowns that reduced our gross margin.            
(Id. ¶ 120 (emphasis omitted).)  Cornell stated that much of the excess inventory was in 
“bulky” categories such as “kitchen appliances, TVs and outdoor furniture”—products 
within Target’s HHGs categories, which the CWs and Target employees had spoken about.  
(Id. ¶ 118.)  On this news, Target’s stock price declined $53.67 per share, or nearly 25%, 
from a closing price of $215.28 per share on May 17, 2022, to close at $161.61 per share 
on May 18, 2022. (Id. ¶ 124.)                                             
V.   THIS ACTION                                                          
Plaintiffs commenced this action in March 2023.  (Doc. No. 1.)  In their Amended 
Complaint, Plaintiffs assert two claims.  (See Am. Compl.)  Count I is a claim for securities 
fraud  under  Section  10(b)  of  the  Exchange  Act,  15  U.S.C.  § 78j(b),  and  the  SEC’s 
implementing Regulation, Rule 10b-5, 
17 C.F.R. § 240
.10b-5, against all Defendants.  (Id. 

¶¶ 170–80.)  Count II is a claim of controlling-person liability under Section 20(a) of the 
Exchange Act against the Individual Defendants.  (Id. ¶¶ 181–85.)         
                      DISCUSSION                                     
Defendants move to dismiss the Amended Complaint pursuant to Federal Rule of 
Civil Procedure 12(b)(6).  A complaint must present “a short and plain statement of the 

claim showing that the pleader is entitled to relief.”  Fed. R. Civ. P. 8(a)(2); see also Braden 
v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009).  To survive a motion to dismiss 
under Rule 12(b)(6), the complaint “must contain sufficient factual material, accepted as 
true, to ‘state a claim to relief that is plausible on its face.’”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009) (quoting Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 570
 (2007)).  A 
pleading  has  facial  plausibility  when  its  allegations  “allow[]  the  court  to  draw  the 

reasonable inference that the defendant is liable for the misconduct alleged.”  
Id.
  In this 
analysis, the Court construes the allegations and draws inferences from them in the light 
most favorable to the plaintiff.  Park Irmat Drug Corp. v. Express Scripts Holding Co., 
911 F.3d 505, 512
 (8th Cir. 2018).                                            
Defendants argue that Plaintiffs’ allegations do not satisfy the heightened pleading 

standards set forth in the Private Securities Litigation Reform Act (PSLRA), 15 U.S.C. 
§ 78u-4(b, which applies to their claims.  (Doc. No. 81.)  As discussed below, the Court 
agrees.                                                                   
I.   FAILURE TO ADEQUATELY ALLEGE FALSITY IN COUNT I                      
Section 10(b) of the Exchange Act makes it unlawful “[t]o use or employ, in 

connection with the purchase or sale of any security . . . any manipulative or deceptive 
device or contrivance in contravention of such rules and regulations as the [SEC] may 
prescribe.”  15 U.S.C. § 78j(b).  Rule 10b-5 also makes it unlawful to, among other things, 
“make any untrue statement of a material fact or to omit to state a material fact necessary 
in order to make the statements made, in the light of the circumstances under which they 
were made, not misleading.”  
17 C.F.R. § 240
.10b-5(b).  Together, Section 10(b) and Rule 

10b-5 create a private cause of action for fraud.  See Halliburton Co. v. Erica P. John Fund, 
Inc., 
573 U.S. 258
, 267 (2014).  A claim for securities fraud under Section 10(b) and Rule 
10b-5 has the following six elements: “(1) a material misrepresentation or omission by the 
defendant; (2) scienter; (3) a connection between the misrepresentation or omission and 
the purchase or sale of a security; (4) reliance upon the misrepresentation or omission; 

(5) economic loss; and (6) loss causation.”  
Id.
 (quotation omitted).     
In addition to the Iqbal/Twombly pleading standard, when a plaintiff has alleged 
securities  fraud  claims,  the  complaint  is  also  subject  to  the  heightened  pleading 
requirements of the PSLRA, which incorporates the standards of and supersedes reliance 
on Federal Rule of Civil Procedure 9(b).  In re Navarre Corp. Sec. Litig., 
299 F.3d 735, 742
 (8th Cir. 2002); see Fed. R. Civ. P. 9(b) (setting forth that a party alleging fraud must 
“state with particularity the circumstances constituting fraud” but that “[m]alice, intent, 
knowledge, and other conditions of a person’s mind may be alleged generally”).  The 
PSLRA is distinct from Rule 9(b) because it requires that falsity and scienter be pleaded 
with particularity.  Navarre, 
299 F.3d at 742
.                            

Defendants argue that Plaintiffs’ allegations do not satisfy the heightened PSLRA 
standard in any of the elements of their claim.  The Court begins and ends its analysis of 
Count I with the falsity element.7  (Doc. No. 83 at 12–37.)  Under the PSLRA, the 
complaint must “specify each false statement or misleading omission and explain why the 
omission was misleading.”  15 U.S.C. § 78u-4(b)(1).  The complaint must set forth the 
“who, what, when, where and how of the misleading statements or omissions,” In re 2007 

Novastar Fin. Inc., Sec. Litig., 
579 F.3d 878, 882
 (8th Cir. 2009) (quotation omitted), and 
“indicate why the alleged misstatements would have been false or misleading at the several 
points in time in which it is alleged they were made.”  In re Hutchinson Tech., Inc. Sec. 
Litig., 
536 F.3d 952
, 958–59 (8th Cir. 2008) (quotation omitted).  Defendants argue that 
there are “universal defects” with Plaintiffs’ falsity allegations, namely that Plaintiffs have 

failed to allege the basis for the CWs’ knowledge and that some of the CWs’ statements 
are consistent with Target’s statements, while others are contradicted by Target’s public 
disclosures.  (Doc. No. 83 at 23–30.)  In addition, Defendants argue that the alleged 
misstatements  are  nonactionable  for  independent  reasons,  which  vary  based  on  the 
category of statement at issue.  (Id. at 13, 30.)                         




7 In light of the Court’s decision that Plaintiffs have failed to plead falsity, the Court need 
not reach the question of whether Plaintiffs have adequately pleaded scienter.   
A.   Universal Defects                                               
Allegations based on confidential witness accounts in securities-fraud actions are 

distinct from other factual allegations contained in a complaint (which courts must accept 
as true on a motion to dismiss), and courts view them with skepticism.  See Minneapolis 
Firefighters’ Relief Ass’n v. MEMC Elec. Materials, Inc., 
641 F.3d 1023, 1030
 (8th Cir. 
2011) (disregarding plaintiff’s reliance on allegations of confidential sources and affirming 
dismissal for failure to state a securities-fraud claim); see also Trs. of Welfare & Pension 
Funds of Loc. 464A - Pension Fund v. Medtronic PLC, No. 22-CV-2197 (KMM/JFD), 

2024 WL 1332262
, at *30 (D. Minn. Mar. 28, 2024) (granting motion to dismiss for failure 
to state a securities fraud claim and noting that courts “treat allegations in a complaint 
based  on  the  accounts  of  confidential  witnesses  with  skepticism”);  Shoemaker  v. 
Cardiovascular Sys. Inc., 
300 F. Supp. 3d 1046, 1055
 (D. Minn. 2018) (granting motion to 
dismiss for failure to state a securities fraud claim and noting that “courts are not required 

to wholly accept as true statements from a confidential witness”).  When determining 
whether a plaintiff’s allegations satisfy the PLSRA’s heightened pleading standard, courts 
consider, among other things, whether the complaint contains allegations that support a 
confidential witness’s basis of knowledge.  In re NVE Corp. Sec. Litig., 
551 F. Supp. 2d 871, 881
 (D. Minn. 2007), aff’d, 
527 F.3d 749
 (8th Cir. 2008).            

Dismissal is proper where the plaintiff fails to adequately allege the confidential 
witness’s basis of knowledge and the confidential witness’s statement is the only allegation 
supporting the alleged misrepresentation.  See, e.g., In re Hutchinson Tech., 536 F.3d at 
959–60  (affirming  dismissal  for  failure  to  state  a  securities  fraud  claim  because  the 
complaint  lacked  “any  allegations  showing  the  basis  of”  the  confidential  witness’s 
knowledge,  and  the  confidential  witness  “provided  the  only  basis  for”  the  alleged 

misrepresentation); Pound v. Stereotaxis, Inc., 
8 F. Supp. 3d 1157, 1166
 (E.D. Mo. 2014) 
(noting same).                                                            
The allegations in the Amended Complaint do not satisfy the PSLRA’s heightened 
pleading requirement because they fail to adequately set forth any of the three CWs’ basis 
for  knowing  facts  that  support  the  heart  of  the  alleged  omission:  that  Target  had 
“abandoned its customer-focused purchasing strategy” in favor of “indiscriminately buying 

large quantities of inventory” that consumers did not want, particularly HHGs.  (Am. 
Compl. ¶ 39.)  Plaintiffs fail to allege facts to support the notion that the CWs had personal 
knowledge of Target’s inventory procurement processes (e.g., what Target’s consumer 
data showed, how the data factored into Target’s inventory procurement, or how the data 
was inconsistent with Targets actions).  Plaintiffs have also failed to allege how any of the 

CWs knew that Defendants had abandoned Target’s inventory procurement policy in favor 
of intentionally ordering inventory without regard to consumer demand.  For instance, there 
are no allegations that any of the CWs were involved at the merchandise-procurement stage 
or spoke with anybody involved at that stage who shared knowledge of an intentional shift 
in the inventory-procurement policy.  Additionally, there are no allegations to suggest any 

of the CWs analyzed Target’s companywide sales or demand, knew customer-purchasing 
patterns across Target’s business, let alone what merchandise Target was purchasing and 
when.  Rather, Plaintiffs allege that the CWs had knowledge of Target’s inventory after it 
was procured, namely that they observed inventory levels increasing after the fact, which 
is not enough to survive a motion to dismiss.  See In re Hutchinson Tech. Inc. Sec. Litig., 
502 F. Supp. 2d 884, 895
 (D. Minn. 2007) (concluding that CW’s observation that returns 

had decreased did not support allegation that the company’s return allowances were 
inadequate), aff’d, 
536 F.3d 952
.  Moreover, the CWs’ observations were consistent with 
Target’s public statements that it was preordering merchandise and investing in increased 
inventory.  (See Doc. No. 84, Ex. L at 31.)  Target’s audited financial statements show that 
consumer demand for HHGs was consistently increasing throughout 2021, on top of record 
increases in 2020.  (Id., Ex. K.)                                         

Thus,  drawing  all  reasonable  inferences  in  Plaintiffs’  favor,  the  allegations 
contained in the Amended Complaint fail to adequately allege falsity, in part, because they 
do not set forth facts demonstrating the CWs’ basis for knowing the alleged omission.   
B.   Independent Grounds                                             
Defendants group the twenty alleged misstatements into six categories: (1) demand 

warnings;  (2)  insight  statements;  (3)  investment  statements;  (4)  flow  statements;  
(5) historic statements; and (6) markdown projections.  Defendants then contend that the 
six categories of statements constitute forward-looking statements, statements of corporate 
optimism, and opinion statements, which are nonactionable under the PSLRA.  (Doc. No. 
83 at 35–47.)  The Court agrees.                                          

Under  the  PSLRA’s  “safe-harbor”  provisions,  a  defendant’s  forward-looking 
statements  are  nonactionable  if  they  are  accompanied  by  “meaningful  cautionary 
statements,” are “immaterial,” or made without actual knowledge of falsity.  15 U.S.C. 
§ 78u-5(c); see also Julianello v. K-V Pharm. Co., 
791 F.3d 915
, 920–21 (8th Cir. 2015).  
Forward-looking statements include the following types of statements: “(1) projections of 
revenues  or  other  financial  items,  (2)  statements  of  plans  and  objectives  for  future 

operations, and (3) statements of the assumptions underlying the previous two categories.”  
K-V Pharm, 
791 F.3d at 921
 (citing 15 U.S.C. § 78u-5(i)(1)).  “In determining whether a 
statement  is  truly  forward-looking,  the  determinative  factor  is  not  the  tense  of  the 
statement; instead, the key is whether its truth or falsity is discernible only after it is made.”  
Id. (quotation omitted).  In addition, a statement that accurately reports past events or 
historic performance cannot support a securities fraud action.  In re Marion Merrell Dow 

Inc., Sec. Litig. II, No. 93-0251-CV-W-6, 
1994 WL 396187
, at *3–4 (W.D. Mo. July 18, 
1994); see also In re Medtronic Inc., Sec. Litig., 
618 F. Supp. 2d 1016, 1031
 (D. Minn. 
2009) (concluding that company’s public statements were nonactionable because they 
reported accurate historical financial information).                      
The Court considers each of the twenty statements, by category, to determine 

whether they are actionable under the PSLRA.                              
     i.   Demand Warnings                                            
The first category of allegedly misleading statements concerns Statements 10 and 
20, warnings about demand that Target included in its Form 10-K and Form 10-Q filings 
with the SEC.  (Am. Compl. ¶¶ 94, 114.)  These filings disclosed the following three risks 

that could occur if Target did not obtain accurate and relevant data on and anticipate and 
respond  quickly  to  changing  consumer  preferences:  (1)  lost  sales,  (2)  spoilage,  and 
(3) increased  inventory  markdowns  that  could  adversely  affect  Target’s  results  of 
operation.  (Id.)  According to Plaintiffs, these statements were  materially false and 
misleading because Defendants had stopped procuring inventory based on consumer data 
and  insights,  resulting  in  unwanted  inventory  that  Target  could  not  sell,  and  that 

necessitated large discounts and corresponding write-offs.  The Court disagrees and finds 
that the statements are nonactionable for the following two reasons.      
First, Plaintiffs have failed to plausibly allege that the statements were made “with 
actual  knowledge  .  .  .  that  the  statement[s] w[ere]  false  or  misleading.”    15  U.S.C. 
§ 78u‑5(c)(1)(B).  The Amended Complaint contains no allegation that when Defendants 
made these statements on November 24, 2021, and March 9, 2022, they knew that lost 

sales, spoilage, and increased inventory markdowns had already occurred.  Trs. of Welfare, 
2024 WL 1332262
, at *15 (finding forward-looking statements nonactionable under the 
PSLRA’s safe-harbor provisions where plaintiffs did not plausibly allege that at the times 
defendants made the forward-looking statements, they knew that the potential risk about 
which they cautioned had already been realized).                          

Second,  the  allegations  do  not  support  an  inference  that  the  statements  were 
materially false.  15 U.S.C. § 78u-5(c)(1)(A) (stating the persons “shall not be liable with 
respect to any forward-looking statement . . . to the extent that . . . the forward-looking 
statement is . . . immaterial”).  The most support Plaintiffs seem to offer for such an 
allegation comes from CW-3’s statement that by June 2021, Target corporate headquarters 

had directed increasing markdowns of certain overstocked products.  (Am. Compl. ¶ 72.)  
However, these statements say nothing of magnitude or degree; without more, they cannot 
support an inference that the unqualified markdowns would materially harm Target’s 
operations.  Moreover, audited financial statements show that sales of HHGs increased 
throughout 2021.  (See Doc. No. 84, Ex. K.)  Specifically, hardline sales in 2021 increased 
48% from 2019 and 12% from 2020, and home goods increased 40% from 2019 and 11% 

from 2020.  (Id.)  Given this increase, the Court cannot draw any inference that the demand 
statements were materially false and misleading.                          
     ii.  Insight Statements                                         
The second category of allegedly misleading statements concerns Statements 1 and 
12, two statements made during Target’s Q3 and Q4 2021 earnings calls.  (Am. Compl. 
¶¶ 81, 98.)  According to Plaintiffs, these insight statements were materially false and 

misleading  because  as  of  June  2021,  Target  was  not  procuring  inventory  based  on 
consumer demand.  The Court disagrees and finds that the statements are nonactionable 
optimistic rhetoric.                                                      
A statement is nonactionable, under Section 10(b), if “a reasonable investor could 
not have been swayed by the statement.”  City of Plantation Police Officers Pension Fund 

v. Meredith Corp., 
16 F.4th 553, 556
 (8th Cir. 2021) (quotation omitted).  “Vague or 
optimistic rhetoric—sometimes called corporate ‘puffery’—falls into this category.”  
Id.
 
(quotation omitted).  The insight statements at issue here reference Target’s continuous 
evaluation of its guests’ mindset, “which serves as a North Star for all [its] strategies and 
decisions,” as well as the fact that Target listens “to the everchanging wants and needs of 

[its] guests.”  (Am. Compl. ¶¶ 81, 98.)  Such statements constitute quintessential examples 
of nonactionable corporate puffery.  Meredith, 
16 F.4th at 557
 (deeming references to 
“proven strategies” inactionable corporate puffery); see also Kusnier v. Virgin Galactic 
Holdings, Inc., 
639 F. Supp. 3d 350
, 374 (E.D.N.Y. 2022) (concluding that defendant’s 
statement of “uncompromising commitment to . . . customer satisfaction” was “pure 
puffery”); In re CenturyLink Sales Pracs. & Sec. Litig., 
403 F. Supp. 3d 712
, 727 (D. Minn. 

2019) (noting that “in many instances, statements about meeting customer needs could be 
puffery” but not where it is alleged that defendant’s financial performance stemmed, in 
material part, from fraud on customers); City of Warren Police & Fire Ret. Sys. v. Foot 
Locker, Inc., 
412 F. Supp. 3d 206
, 221 (E.D.N.Y 2019) (interpreting statements that 
defendant “understands what its customers want and has a connectivity with its consumer” 
as “plainly puffery” (quotations omitted)).  Thus, no reasonable investor could have been 

swayed by Defendants’ vague, optimistic insight statements.               
     iii.  Investment Statements                                     
The third category of allegedly misleading statements concerns Statements 3, 5, 6, 
16, and 17, which comprise five statements made during the Q3 2021 earnings call, the 
question-and-answer session that immediately followed, the Bloomberg interview, and in 

the Form 10-K.  (Am. Compl. ¶¶ 81, 84, 86, 105, 108.)  The Defendants’ statements express 
generic  optimism  about  Target’s  inventory  investments,  describing  its  inventory  as 
“healthy” and “well-positioned,” and stating that they felt good about it.  (Id. ¶¶ 81, 84, 86, 
105.)  The Form 10-K also described how Target carefully plans seasonal inventory levels 
to  minimize  markdowns  and  achieve  effective  inventory  management.    (Id.  ¶ 108.)  

According to Plaintiffs, these statements were materially false and misleading because 
Target  had  no  basis  to  view  its  inventory  positively  after  experiencing  overstocked 
inventory as a result—Plaintiffs allege—of no longer considering consumer demand when 
procuring inventory.  Again, the Court disagrees, concluding that these statements are also 
nonactionable corporate puffery.                                          

Previous  courts  have  reached  the  same  conclusion concerning  nearly  identical 
positive inventory characterizations.  See, e.g., Trs. of Welfare, 
2024 WL 1332262
, at *30 
(finding defendant’s statement that they “felt really good about the pipeline” for products 
was an inactionable statement of optimism and opinion (quotation omitted)); In re Target 
Corp. Sec. Litig., 
955 F.3d 738
, 743 n.2 (8th Cir. 2020) (finding defendant’s statement that 
they “feel really good about where we are today” was nonactionable puffery); In re 

Hutchinson  Tech.,  
536 F.3d at 960
  (affirming  district  court’s  determination  that 
defendant’s statement that it was “well-positioned” was too vague); see also Robeco Cap. 
Growth Funds SICAV – Robeco Glob. Consumer Trends v. Peloton Interactive, Inc., No. 
21-CV-9582  (ALC)(OTW),  
2024 WL 4362747
,  at  *12  (S.D.N.Y.  Sept.  30,  2024) 
(concluding  that  defendant’s  forward-looking  statement  about  its  “healthy”  inventory 

heading into a busy time of year was “precisely the type of vague expressions of optimism” 
that courts dismiss).  Moreover, the context of the investment statements at issue here 
would have made clear to a reasonable investor that the health of Target’s inventory was 
relative to the persistent inventory shortages resulting from the unprecedented COVID-19 
pandemic and its effect on the global economy.  See In re K-tel Int’l, Inc. Sec. Litig., 
300 F.3d 881, 897
  (8th  Cir.  2002)  (“[I]f  no  reasonable  investor  could  conclude  public 
statements, taken together and in context were misleading, then the issue is appropriately 
resolved as a matter of law.”)  Thus, the investment statements cannot support an actionable 
securities fraud claim.                                                   
     iv.  Flow Statements                                            
The next category of allegedly misleading statements concerns Statements 2, 4, and 

15, three statements made during Target’s Q3 and Q4 2021 earnings calls concerning the 
flow of inventory.  (Am. Compl. ¶¶ 81, 82, 103.)  The Defendants’ statements describe 
Target’s efforts to move the right inventory “to the right place at the right time” (id. ¶¶ 81, 
82), as well as how “[s]peed and flow of inventory is the key to the whole game” and “there 
was a lot of headroom for growth” because inventory was constantly moving through 
Target’s “largest stores.”  (Id. ¶ 103.)  Again, Plaintiffs argue these statements were 

materially  false  and  misleading  because  Target  had  no  basis  to  view  its  inventory 
positively.  The Court disagrees and finds the flow statements are nonactionable for the 
following two reasons.                                                    
First,  the  mere  allegation  that  Target  procured  inventory  without  regard  for 
consumer demand does not necessary establish the falsity of Target’s statement that it was 

trying to get the right inventory to the right place at the right time.  See Foot Locker, 412 
F. Supp. 3d at 224 (noting that confidential witnesses’ statements that retailer bought “large 
quantities of undesirable merchandise in order to obtain desirable merchandise” did not 
undercut the retailer’s statements that it was “try[ing] to get what it thought was the 
appropriate amount for its stores” or “working to improve allocation to get the right product 

to the right place, right time” (quotation omitted)).  Nor does it necessarily mean that 
Target’s other flow statements were false.                                
Second, as with the insight and investment statements discussed above, the flow 
statements are also examples of vague, optimistic rhetoric that constitutes nonactionable 
puffery.  See U.S. Bank Nat’l Ass’n v. PHL Variable Ins. Co., No 12-CV-6811 (CM)(JCF), 
2013 WL 791462
, at *6 (S.D.N.Y. Mar. 5, 2013) (“Where a representation is subject to 

varying interpretations depending upon varying standards different persons use, classic 
puffery is involved.” (quotation omitted)); Gammel v. Hewlett-Packard Co., 
905 F. Supp. 2d 1052
 (C.D. Cal. 2012) (concluding that alleged misstatements that corporation would 
“draw on its deep executive bench to position the right leaders in the right roles to 
accelerate  the  long-term  growth”  was  nonactionable  puffery).    Therefore,  the  flow 
statements are nonactionable.                                             

     v.   Historic Statements                                        
The next category of allegedly misleading statements concerns Statements 7, 8, 9, 
11, 18, and 19, which comprise six statements made in Target’s Form 10-Q, press release, 
Q4 2021 earnings call, and Form 10-K.  (Am. Compl. ¶¶ 88, 90, 92, 96, 110, 112.)  These 
statements report on  Target’s past  financial and operating results, gross margin rate, 

inventory position, and certain company actions.  (See id.)  According to Plaintiffs, these 
statements were materially false and misleading because they misled investors as to the 
likelihood of future markdowns.  (Id. ¶¶ 91, 97, 111.)  The Court disagrees and finds these 
statements are nonactionable because they are reports of past performance or events and 
the Amended Complaint contains no allegations that the historic statements are false or 

inaccurate.  See In re Marion Merrell Dow, 
1994 WL 396187
, at *3–4 (listing cases and 
noting that “statements pertaining to past performance not alleged to be inaccurate are 
clearly not materially misleading”); see also In re Medtronic, 
618 F. Supp. 2d at 1031
 
(dismissing for failure to state a securities fraud claim because the complaint made no 
allegations that the statements at issue, which concerned past sales and economic success, 
were inaccurate).                                                         

     vi.  Markdown Projections                                       
The final category of allegedly misleading statements concerns Statements 13 and 
14, which  comprise  two  statements  made during  the  Q4  2021 earnings  call  and  the 
question-and-answer session immediately following that call.  (Am. Compl. ¶¶ 100, 101.)  
The Defendants’ statements relate to their projections for a “small increase in markdown 
rates.”  (Id. ¶ 100.)  According to Plaintiffs, these statements were materially false and 

misleading  because  Defendants  knew  that  HHG  inventory  would  need  “significant 
markdowns and write-offs the immediately following quarter,” yet understated their extent.  
(Id. ¶ 102.)  The Court disagrees.                                        
The  markdown  statements  are  nonactionable  because  Plaintiffs  have  failed  to 
plausibly  allege  that  at  the  time  the  statements  were  made  Defendants  had  “actual 

knowledge . . . that the statement[s] w[ere] false or misleading.”  15 U.S.C. § 78u-
5(c)(1)(B(ii)(II).  Specifically, Plaintiffs have failed to allege facts showing that Defendants 
knew—at the time these statements were made—that demand would rapidly change later 
that month, necessitating additional markdowns beyond those contemplated at that time.  
See In re Target Sec. Litig., 
275 F. Supp. 3d 1063, 1071
 (D. Minn. 2017) (“[M]erely 

pleading that the prediction must have been false mid-year because it conflicts with year-
end facts [is] an unsatisfactory explanation for ‘why’ the mid-year statement was false 
when made.”); In re Leapfrog Enter., Inc. Sec. Litig., 
200 F. Supp. 3d 987, 1005
 (N.D. Cal. 
2016) (finding that just because inventory did not move as quickly as defendants projected 
it would did not mean projections were false when made).                  

In  sum,  drawing  all  reasonable  inferences  in  Plaintiffs’  favor,  the  Court  also 
concludes that the allegations contained in the Amended Complaint fail to adequately 
allege falsity because the statements identified by Plaintiffs are protected by the PSLRA’s 
safe-harbor provisions, namely, that they are material and that the Defendants had actual 
knowledge that the statements were false at the time they were made.  Additionally, many 
of the statements are nonactionable statements of corporate optimism, opinion statements, 

or uncontested statements of past performance.                            
For these reasons, the Court will dismiss Count I.                   
II.  COUNT II                                                             
Because Plaintiffs have failed to adequately allege their Section 10(b) and Rule 10b-
5 claim, the claim under Section 20(a) also fails as a matter of law.  Lustgraaf v. Behrens, 

619 F.3d 867, 874
 (8th Cir. 2010) (“The plain language of the control-person statute 
dictates that, absent a primary violation, a claim for control-person liability must fail.”).  
Therefore, the Court will also dismiss Count II.                          
III.  FORM OF DISMISSAL                                                   
“[C]ourts  ultimately  have  discretion  to  decide  between  a  with-prejudice  and 

without-prejudice dismissal.”  Miles v. Simmons Univ., 
514 F. Supp. 3d 1070
, 1080 (D. 
Minn.  2021).    Dismissal  with  prejudice  is  appropriate  “when  a  plaintiff  has  shown 
persistent pleading failures despite one or more opportunities to amend.”  
Id.
 (quotation 
omitted).  However, “when a plaintiff’s claims might conceivably be repleaded with 
success, . . . dismissal  without  prejudice  may  be  justified.”    
Id.
  (quotations  omitted).  
Plaintiffs state that they intend to file a motion for leave to amend, pursuant to D. Minn. 

Local Rule 15.1(b), if the Court dismisses their complaint in its entirety.  (Doc. No. 91 at 
73 n.40.)                                                                 
Before the present motion was filed, Plaintiffs requested, and were granted, an 
extension to file their amended complaint.  (Doc. Nos. 60, 65, 70.)  Plaintiffs also could 
have filed a motion for leave to amend, pursuant to Rule 15.1(b), upon reviewing the 
arguments Defendants raised in their motion to dismiss, but they chose to stand by the 

Amended Complaint in its present form.  Moreover, the Court concludes that the factual 
deficiencies here cannot conceivably be cured.  Therefore, the Court will not entertain a 
motion brought pursuant to Rule 15.1(b), and this action will be dismissed with prejudice.    

ORDER

Based on the foregoing, and on all of the files, records, and proceedings herein, 

IT IS HEREBY ORDERED THAT:                                                
1.   Defendants Target Corporation’s, Brian C. Cornell’s, Michael J. Fiddelke’s, 
     A. Christina Hennington’s, and John J. Mulligan’s Motion to Dismiss (Doc. 
     No. 81) is GRANTED; and                                         

2.   The  Amended  Complaint  (Doc.  No.  70)  is  DISMISSED  WITH   
     PREJUDICE.                                                      

LET JUDGMENT BE ENTERED ACCORDINGLY.                                 


Dated:  November 15, 2024               /s/ Jeffrey M. Bryan              
                                   Judge Jeffrey M. Bryan            
                                   United States District Court      

Trial Court Opinion

            UNITED STATES DISTRICT COURT                             
                DISTRICT OF MINNESOTA                                


Rafael E. Perez, individually and on   Case No. 23-CV-00769 (JMB/TNL)     
behalf of all others similarly situated, and                              
Terry and Diane Van Der Tuuk Living Trust,                                

          Plaintiffs,                                                

    v.                                                                         ORDER 

Target Corporation, Brian C. Cornell,                                     
Michael J. Fiddelke, A. Christina                                         
Hennington, and John J. Mulligan,                                         

          Defendants.                                                


Garrett D. Blanchfield, Jr., and Roberta A. Yard, Reinhardt Wendorf & Blanchfield, 
Minneapolis, MN; Carl Malmstrom (pro hac vice), Wolf Haldenstein Adler Freeman & 
Herz LLC, Chicago, IL; Shannon L. Hopkins (pro hac vice), Levi & Korsinsky, LLP, New 
York, NY; and Gregory M. Potrepka (pro hac vice), Levi & Korsinsky, LLP, Stamford, 
CT, for Lead Plaintiff Terry and Diane Van Der Tuuk Living Trust.         
Garrett D. Blanchfield, Jr., and Roberta A. Yard, Reinhardt Wendorf & Blanchfield, 
Minneapolis, MN, for Plaintiff Rafael E. Perez.                           
Jeffrey  P.  Justman,  Faegre  Drinker  Biddle  &  Reath  LLP,  Minneapolis,  MN;  Sandra 
Grannum (pro hac vice), Faegre Drinker Biddle & Reath LLP, Florham Park, NJ; and 
Alexander J. Rodney (pro hac vice), Sandra Goldstein (pro hac vice), and Stefan H. 
Atkinson (pro hac vice), Kirkland & Ellis LLP, New York, NY, for Defendants Target 
Corporation, Brian C. Cornell, Michael J. Fiddelke, A. Christina Hennington, and John J. 
Mulligan.                                                                 


This matter is before the Court on Defendants Target Corporation’s (Target), Brian 
C. Cornell’s, Michael J. Fiddelke’s, A. Christina Hennington’s, and John J. Mulligan’s 
(together, Defendants) motion to dismiss (Doc. No. 81) Lead Plaintiff Terry and Diane Van 
Der Tuuk Living Trust’s (the Trust) Amended Complaint, which alleges violations of 
sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the Exchange Act), 
15 U.S.C. §§ 78j(b) and 78t(a), and the Securities and Exchange Commission’s (SEC) 

implementing regulation, Rule 10b-5, 
17 C.F.R. § 240
.10b-5, on behalf of itself and all 
persons who purchased or otherwise acquired Target common stock between November 
17, 2021 and May 17, 2022 (the Class Period).  For the reasons explained below, the Court 
grants Defendants’ motion in its entirety.                                
                    BACKGROUND1                                      

I.   THE PARTIES                                                          
Target is a national retailer.  (Doc. No. 70 [hereinafter, “Am. Compl.”] ¶ 29.)  Its 
common stock trades on the New York Stock Exchange.  (Id. ¶ 17.)  Defendants Cornell, 
Fiddelke, Hennington, and Mulligan (together, Individual Defendants) were executive 
officers of Target during the Class Period.2  (Id. ¶¶ 18–21.)             
Plaintiffs purchased Target common stock during the Class Period.  (Id. ¶¶ 14, 163.)  

As described more fully below, Plaintiffs allege that the Defendants made materially false 
and misleading statements to investors during the Class Period while in possession of 
material, non-public adverse information about Target that they purposefully concealed 


1 The following facts are drawn from the Amended Complaint, as well as “documents 
incorporated into the complaint by reference, and matters” subject to judicial notice, such 
as public SEC filings, stock price history, and industry trends.  Tellabs, Inc. v. Makor Issues 
& Rts., Ltd., 
551 U.S. 308, 322
 (2007).                                   

2 Cornell was Target’s Chief Executive Officer and Board Chairman.  (Id. ¶ 18.)  Fiddelke 
was Target’s Executive Vice President (EVP) and Chief Financial Officer.  (Id. ¶ 19.)  
Hennington was Target’s EVP and Chief Growth Officer.  (Id. ¶ 20.)  Mulligan was 
Target’s EVP and Chief Operating Officer.  (Id. ¶ 21.)                    
from investors.  (Id. ¶ 24.)  Plaintiffs further allege that Fiddelke, Cornell, and Hennington 
had a motive to mislead investors because they executed suspicious stock sales during the 

Class  Period  while  in  possession  of  material,  non-public  information  about  Target’s 
inventory overstock that was not disclosed to investors and while Target’s common stock 
price  was  artificially  inflated  due  to  Defendants’  materially  false  and  misleading 
statements.  (Id. ¶¶ 144–49.)                                             
II.  ALLEGATIONS OF DECLINING DEMAND                                      
In  2020,  when  some  businesses  were  forced  to  close  due  to  the  COVID-19 

pandemic, Target was permitted to remain open as an essential business.  (Id. ¶ 2.)  During 
that year, Target reported record sales growth across each of its five “core” product 
categories: (1) apparel and accessories; (2) beauty and household essentials; (3) food and 
beverage; (4) hardlines; and (5) home furnishings and décor.  (Id. ¶¶ 29–30.)  As consumers 
spent more time at home due to lockdowns, Target’s sales in the hardlines and home goods 

(HHG)3 categories particularly grew, each constituting roughly one fifth of Target’s sales 
going into fiscal year 2021.  (Id. ¶¶ 2, 29.)  Despite this growth, in late 2020, supply chain 
issues prevented Target from keeping its shelves fully stocked, which negatively impacted 
its revenue.  (Id. ¶ 3.)                                                  
By early- to mid-2021, when COVID restrictions were lifting and non-essential 

businesses reopening, Plaintiffs allege that consumers’ shopping habits shifted away from 

3 The hardlines category includes electronics, toys, entertainment, sporting goods, and 
luggage.  (Id. ¶ 29.)  The home goods category includes furniture, lighting, storage, 
kitchenware, small appliances, home décor, bed and bath, home improvement, school and 
office supplies, greeting cards, party supplies, and seasonal merchandise.  (Id.)       
HHGs, causing the availability of those products to increase.  (Id.)  Despite this shift in 
consumer preferences, Plaintiffs allege that by at least June 2021, Target had begun 

preordering large quantities of HHGs to ensure its shelves were stocked going into the 2021 
holiday season.  (Id. ¶¶ 4–5.)  Plaintiffs allege that Target procured this inventory without 
regard  for  consumer  preferences,  which  resulted  in  Target’s  warehouses,  distribution 
centers, and stores becoming overstocked with HHGs by September of 2021.  (Id. ¶ 6.)   
Plaintiffs also allege that during the Class Period, Defendants misled investors by 
making a series of twenty statements.  (Id. ¶¶ 80–115.)  Plaintiffs allege that the twenty 

statements  were  materially  false  and  misleading  for  essentially  the  same  reason: 
Defendants were concealing the fact that Target had “abandoned its customer-focused 
purchasing strategy” in favor of “indiscriminately buying large quantities of inventory” 
that consumers did not want, particularly HHGs.  (Id. ¶ 39.)  Plaintiffs base this allegation 
on statements imputed to three confidential witnesses (CWs)—former Target employees 

who claim to have observed HHG inventory becoming overstocked in the months leading 
up to and through the Class Period.4  (Id. ¶¶ 80–115.)                    
CW-1 was a warehouse associate at Target’s regional distribution center (RDC) in 
Albany, Oregon, which services five states in the Pacific Northwest, during the Class 
Period.  (Id. ¶ 26.)  In that role, CW-1 was responsible for unloading and sorting inventory 


4 Plaintiffs also ask the Court to consider “anonymous employee posts on multiple Internet 
forums for Target employees from across the country” that they argue “corroborate the CW 
accounts.”  (Doc. No. 91 at 29; Am. Compl. ¶¶ 74–78.)  Defendants contend that the Court 
should not consider these posts because “anonymous and unsubstantiated user comments 
badly flunk pleading fraud.”  (Doc. No. 83 at 23 n.10.)  The Court declines to consider 
these posts, but even if it did, they would not have a determinative effect on the outcome. 
received from vendors, selecting inventory to ship to stores, and attending daily shift 
meetings to discuss  the state of inventory  and how it exceeded  the RDC’s intended 
capacity.5  (Id. ¶¶ 46–47, 49–50.)  CW-1 observed inventory levels at the RDC, including 

“stash aisles” of excess inventory and 50 to 100 trailers of inventory in the RDC parking 
lot, and learned through daily meetings with the Senior Director of Distribution (and 
headquarters liaison) of the RDC’s decreasing capacity for inventory.  (Id. ¶¶ 49–54.)   
CW-2 was an operations manager at Target’s flow center warehouse in Logan 
Township, New Jersey, during the Class Period, and was responsible for replenishing 

inventories and fulfilling e-commerce orders for much of the East Coast, including direct-
to-consumer online sales and stores in five states.  (Id. ¶ 56.)  CW-2 observed inventory 
accumulating at the warehouse.  (Id. ¶¶ 58–60.)  CW-2 was also given inventory reports 
from Target headquarters generated from a custom-built warehouse management system.  
(Id. ¶ 61.)                                                               

CW-3 was an executive team lead (ETL) at a major Target store in New York during 
the Class Period, and was responsible for receiving and unloading incoming inventory, 
managing  the  back  stockroom,  getting  inventory  onto  the  sales  floor,  and  fulfilling 
customer orders.  (Id. ¶ 64.)  CW-3 had access to Target’s inventory management data 
system and received directives from headquarters based on data from that system.  (Id. 

¶¶ 67–69.)  CW-3 also communicated directly with ETLs who oversaw other stores in the 


5 “According to CW-1, the overwhelming majority of inventory sold in Target stores flows 
from vendors through Target’s RDCs, save for ‘very few’ products that go straight to 
stores.”  (Am. Compl. ¶ 47.)                                              
same region, as well as the district store director, who visited stores weekly or bi-weekly 
and observed and discussed overstock on the sales floor and in the stockroom with ETLs.  

(Id. ¶ 70.)                                                               
III.  ALLEGATIONS OF FALSE AND MISLEADING STATEMENTS                      
Based on information provided by the CWs, Plaintiffs allege that the following 
twenty statements, made by Defendants across five separate dates during the Class Period, 
were materially false and misleading.                                     

A.   November 17, 2021 Statements                                    
On November 17, 2021, Target held a Q3 2021 earnings call in which it announced 
its third quarter financial results.  (Id. ¶ 80.)  During that call, Hennington claimed that 
Target was using consumer insights to inform its inventory purchasing decisions:  
     We continuously evaluate our guests’ mindset, which serves      
     as a North Star for all our strategies and decisions.  We       
     remain  laser-focused  on  their  experiences  with  us  and    
     expectations of us.  And we strive to build flexibility and     
     agility into our plans to ensure we show up at our best for them 
     during the holidays and all year round.                         

                          ***                                        

     As  [Mulligan]  will  outline  in  more  detail,  our  teams  are 
     working diligently to get the right inventory to the right place 
     at the right time.  Doing so has driven some near-term gross    
     margin  pressure,  appropriate  long-term  investment  in  the  
     relationship  with  our  guests.    Bottom  line,  based  on  the 
     incredible  efforts  of  our  team,  we  feel  good  about  our 
     inventory levels heading into the holiday season.               
(Id. ¶ 81 (Statements 1, 2, and 3) (emphasis in original).)6  On that same call, Mulligan told 
investors that Target was focused on moving appropriate levels of inventory, particularly 

during the prime holiday shopping season, and stated: “On our supply chain team, the focus 
is on moving the right amount of inventory to the right place at the right time.  (Id. ¶ 82 
(Statement 4) (emphasis in original).)  Later during that call, Mulligan reiterated that, 
“while we continue to see some periodic outages across different items and categories, 
we’re entering the holidays with a very healthy inventory position overall.  (Id. ¶ 84 
(Statement 5) (emphasis in original).)                                    

Following Defendants’ prepared statements, the earnings call turned to a question-
and-answer session with securities analysts.  (Id. ¶ 86.)  In response to a question posed 
about how inventory levels were affecting Target’s gross margin, Fiddelke emphasized that 
Target purchased and positioned its inventory with reference to guests’ expectations:  
     As you know, we don’t guide margins specifically out into       
     future quarters.  But I will say and reiterate what I said in my 
     remarks.  I think you’re seeing in the third quarter, the result 
     of some very specific investments we made.  And the biggest     
     of those investments is an investment to make sure we’ve got    
     a great inventory position heading into the fourth quarter.     
     And pulling all the levers within the system to ensure we’re    
     there for the guest has been our priority.  And some of those   
     levers, think of expediting product to come at a cost, and you  
     saw some of that in the third quarter.                          

     But I feel really good about the payoff from an investment      
     decision like that.  We’ve got inventory of $2 billion north of 
     last year, up almost 20% on a year-over-year basis.  And        
     that’s fueling the continued top line growth that we see.  So,  
     I feel really good about the set of investments that we’re      

6 All italicized and bolded text are statements that Plaintiffs allege are false and misleading.  
(Am. Compl. at 28 n.8.)  Additional statements are provided for necessary context.  (Id.)   
     making and how they have us positioned for the back part of     
     the year.                                                       

(Id. ¶ 86 (Statement 6) (emphasis in original).)                          
Plaintiffs allege that the November 17, 2021 statements were materially false and 
misleading because by at least June 2021, Target was not taking customers’ shifting buying 
habits into account but, instead, preordered excess quantities of HHG inventory, which 
resulted in a massive overstock that was not “well-positioned” or “healthy” but that would 
need to be marked down and discounted in order to sell.  (Id. ¶¶ 83, 85, 87.)       
B.   November 24, 2021 Statements                                    
On November 24, 2021, Target filed a Q3 2021 Form 10-Q, which reported its 
financial and operating results for that quarter.  (Id. ¶ 88.)  The Form 10-Q indicated that 

its inventory management aimed to offset supply chain pressures:          
     Since  the  onset  of  the  COVID-19  pandemic,  we  have       
     experienced strong comparable sales growth and significant      
     volatility in our sales category and channel mix, including     
     same-day  fulfillment  options.    Note  4  presents  sales  by 
     category.    We  have  taken  various  actions,  including      
     accelerating purchases of certain merchandise in our core       
     categories and, early in the pandemic, slowing or canceling     
     purchase orders, primarily for Apparel and Accessories.  As a   
     result, during the quarter ended May 2, 2020, we recorded $216  
     million of purchase order cancellation fees in Cost of Sales.   

(Id. (Statement 7) (emphasis in original).)  It also stated that Target’s inventory position 
was a positive driver of the gross margin rate in contrast to negative drivers (e.g., supply 
chain issues), as follows:                                                
     For the three months ended October 30, 2021, our gross margin   
     rate  was  28.0  percent  compared  with  30.6  percent  in  the 
     comparable prior-year period.  This decrease reflected the net  
     impact of[:]                                                    
     •  pressure  from  higher  merchandise  and  freight  costs  and 
     higher  inventory  shrink,  partially  offset  by  the  benefit  of 
     historically low promotional and clearance markdown rates;      
     • supply chain pressure related to increased compensation and   
     headcount in our distribution centers; and                      
     • favorable mix in the relative growth rates of higher and lower 
     margin categories.                                              
(Id. ¶ 90 (Statement 8) (emphasis in original).)                          
The Form 10-Q also informed investors that Target had factored customer sales 
trends in its inventory position, as follows:                             
     Inventory was $15.0 billion as of October 30, 2021, compared    
     with $10.7 billion and $12.7 billion at January 30, 2021, and   
     October 31, 2020, respectively.  The increase over the balance  
     as of October 31, 2020, reflects efforts to align inventory with 
     sales trends.                                                   

(Id. ¶ 92 (Statement 9) (emphasis in original).)  Finally, the Form 10-Q incorporated by 
reference statements in Target’s Form 10-K, which it filed with the SEC on March 10, 
2021, that were purportedly made to warn investors of certain risk factors, as follows: 
     If we do not anticipate and respond quickly to changing         
     consumer  preferences,  our  sales  and  profitability  could   
     suffer.  A large part of our business is dependent on our       
     ability to make trend-right decisions and effectively manage    
     our inventory in a broad range of merchandise categories,       
     including apparel, accessories, home décor, electronics, toys,  
     seasonal offerings, food, and others.  If we do not obtain      
     accurate and relevant data on guest preferences, predict and    
     quickly respond to changing consumer tastes, preferences,       
     spending patterns and other lifestyle decisions, emphasize the  
     correct  categories,  implement  competitive  and  effective    
     pricing  and  promotion  strategies,  or  personalize  our      
     offerings  to  our  guests,  we  may  experience  lost  sales,  
     spoilage, and increased inventory markdowns, which could        
     adversely affect our results of operations.                     

(Id. ¶ 94 (Statement 10) (emphasis in original).)                         
Plaintiffs allege that the November 24, 2021 statements were materially false and 
misleading because the purported risk being warned of had already materialized and 
because Defendants failed to disclose that, in preordering massive quantities of hardline 
and home good inventory, Target had abandoned the use of customer data and insights, 
which was creating an immense overstock of those items, which would eventually need to 
be marked down and discounted.  (Id. ¶¶ 89, 91, 93, 95.)                  
C.   March 1, 2022 Statements                                        
On March 1, 2022, Target announced its 2021 Q4 earnings.  (Id. ¶ 96.)  A press 

release stated that Target’s “[f]ull-year gross margin rate was 28.3 percent, in line with 
28.4 percent in 2020, reflecting pressure from increased supply chain, merchandise, and 
freight costs largely offset by favorable category mix and lower markdowns.”  (Id. 
(Statement 11) (emphasis in original).)                                   
On a Q4 earnings call, Hennington emphasized that Target’s business model, which 

factored in customer preferences, gave the company a unique competitive edge, as follows:  
     We have created momentum through unique and innovative          
     strategies, many of which began long before the onset of the    
     pandemic.  And because of our durable, flexible business        
     model, we have proven we can adapt to any environment.          
     We’ll continue to play offense and accelerate these strategies  
     while listening to the ever-changing wants and needs of our     
     guests to ensure our playbook is a direct reflection of what they 
     have come to expect from Target.                                
(Id. ¶ 98 (Statement 12) (emphasis in original).)  On that same call, Fiddelke discussed 
Target’s plans for markdowns in the coming year, stating, “[W]e’re planning for a small 

increase in markdown rates in 2022 as we move past the dramatically low rates we’ve 
seen over the last couple of years.”  (Id. ¶ 100 (Statement 13) (emphasis in original).)   
Following Defendants’ prepared statements, the call opened up to a question-and-
answer format with securities analysts.  (Id. ¶ 101.)  In response to an analyst question 
about Target’s efficiency in markdowns, Fiddelke said the following:      

     The shape of profit for the year will be like we described,     
     where you could expect it to build over the course of the year.  
     When  it  comes  to  markdowns  specifically,  there’s  some    
     markdowns that we’ve been rooting for returning.  To be         
     better in stock with stronger inventory levels means a few      
     more  clearance  markdowns,  and we’re  planning  for  that     
     outcome in the upcoming year.                                   

(Id. (Statement 14) (emphasis in original).)  When analysts on the call continued to inquire 
about Target stores’ capacity to store inventory, Mulligan said the following: 
     I think the other thing I’d add on is as inventory turns increase 
     with scale, you just push things through faster.  Speed and flow 
     of inventory is the key to the whole game, like we were just    
     talking about with Robby.  And as that happens, we see it in    
     our largest stores, they just move inventory.  It’s constantly  
     moving through.  It shows up at night.  It’s out the store the  
     next day.  That’s capacity.  You’re just moving inventory.  So  
     a lot of headroom for growth from that perspective.             

(Id. ¶ 103 (Statement 15) (emphasis in original).)                        
That  same  day,  Fiddelke  also  took  part  in  an  interview  with  Bloomberg’s 
“Bloomberg Surveillance” television program.  (Id. ¶ 105.)  When asked about how Target 
handled supply chain disruptions and inflation, Fiddelke responded as follows:  
     Well, as you might expect, it’s a situation we monitor really   
     closely  and  I’ll  start  by  just  saying  our  hearts  go  out  to 
     everyone impacted by the situation in Ukraine.  I know it       
     weighs heavily on my mind, our Target team and our guests.      
     We’re  fortunate.    We’ve  got  the  benefit  of  a  really    
     sophisticated supply chain that’s navigated a lot of challenges 
     over the last two years.  Incredibly well.  I feel really good  
     about  our  inventory  position  today,  up  30%  to  last  year.  
     That’s a  testament to us working through some of those         
     supply chain challenges.  So, we should be well positioned to   
     start the year.                                                 

(Id. ¶ 105 (Statement 16) (emphasis in original).)                        
Plaintiffs  allege  that  the  March  1,  2022  statements  were  materially  false  and 
misleading because they failed to disclose that Target had abandoned its “durable, flexible 
business model” as it related to inventory management, “gave the false impression that 
Target was not overstocked in inventory such that the Company would not need to take 
major  markdowns  and  thereby  have  a  higher  gross  margin,”  “gave  the  misleading 
impression that at that time inventory was constantly moving and not building up and that 
Target stores had plenty of inventory capacity,” and because “Defendants had no basis to 
view Target’s inventory increase as positive or its inventory status as ‘well positioned.’”  
(Id. ¶¶ 97, 99, 102, 104, 106.)  Rather, by June 2021, Defendants had begun preordering 
large quantities of hardline and furniture inventory without regard for customer trends.  (Id. 
¶ 106.)    That  inventory  piled  up  in  Target’s  distribution  centers  and  stores  because 
consumers were not buying it and, in turn, Target would be compelled to mark that 
inventory down and write it off the following quarter.  (Id.)             
D.   March 9, 2022 Statements                                        
On March 9, 2022, Target filed a Form 10-K with the SEC, which reported its results 

for Q4 of 2021.  (Id. ¶ 107.)  It told investors the following:           
     Effective inventory management is key to our ongoing success,   
     and we use various techniques including demand forecasting      
     and planning and various forms of replenishment management.     
     We achieve effective inventory management by staying in-        
     stock in core product offerings, maintaining positive vendor    
     relationships,  and  carefully  planning  inventory  levels  for 
     seasonal and apparel items to minimize markdowns.               

(Id. ¶ 108 (Statement 17) (emphasis in original).)  It also described Target’s gross margin 
rate as “a boon,” as follows:                                             
     Our gross margin rate was 28.3 percent in  2021 and 28.4        
     percent in 2020.  This decrease reflected the net impact of[:]  
     • supply chain pressure related to increased compensation and   
     headcount in our distribution centers, partially offset by the  
     small net benefit of a higher percentage of digital sales fulfilled 
     through our lower-cost same-day fulfillment options;            
     •  higher  merchandise  and  freight  costs  partially  offset  by 
     historically low promotional and clearance markdown rates;      
     and                                                             
     • favorable mix in the relative growth rates of higher and      
     lower margin categories.                                        
(Id. ¶ 110 (Statement 18) (emphasis in original).)                        
The Form 10-K also represented that Target’s year-end 2021 inventory was up by 
$3 billion from 2020 because “[t]he increase in inventory levels reflect our efforts to align 
inventory with sales trends, and elevated in-transit inventory related to import supply chain 
delays.”  (Id. ¶ 112 (Statement 19) (emphasis in original).)  Finally, the Form 10-K 
purported to warn investors of the risk that Target’s business could be negatively impacted 
if Target failed to adapt to changing consumer buying behaviors:          

     If we do not anticipate and respond quickly to changing         
     consumer  preferences,  our  sales  and  profitability  could   
     suffer.  A large part of our business is dependent on our ability 
     to  make  trend-right  decisions  and  effectively  manage  our 
     inventory  in  a  broad  range  of  merchandise  categories,    
     including apparel, accessories, home décor, electronics, toys,  
     seasonal offerings, food and beverage, and others.  If we do not 
     obtain  accurate  and  relevant  data  on  guest  preferences,  
     predict  and  quickly  respond  to  changing  consumer          
     preferences, spending patterns, and other lifestyle decisions,  
     emphasize the correct categories, implement competitive and     
     effective pricing and promotion strategies, or personalize our  
     offerings to our guests, we may experience lost sales, spoilage, 
     and increased inventory markdowns, which could adversely        
     affect  our  results  of  operations.    During  the  COVID-19  
     pandemic, many guests significantly reduced their spending on   
     dining, travel, lodging, and other leisure activities outside their 
     homes, which may have contributed to our increased sales,       
     particularly  for  essential  items  and  merchandise  associated 
     with guests spending more time at home.  If we are unable to    
     effectively adapt if or when guests increase spending on other  
     categories, it could lead to lower sales and adversely affect   
     our results of operations.                                      

(Id. ¶ 114 (Statement 20) (emphasis in original).)                        
Plaintiffs  allege  that  the  March  9,  2022  statements  were  materially  false  and 
misleading  because  the  purported  risk  being  warned  of  had  already  materialized, 
Defendants  were  not  “carefully  planning  inventory  levels,”  “achiev[ing]  effective 
inventory management,” or “align[ing] inventory with sales trends” and did not have a 
“favorable mix.”  (Id. ¶¶ 109, 111, 113, 115.)  Rather, by at least June 2021, Defendants 
purposefully preordered large quantities of hardline and furniture inventory without regard 
for customer trends.  (Id.)  That inventory piled up in Target’s distribution centers and 
stores because consumers were not buying it and, in turn, Target had been and would be 
compelled to mark that inventory down and write it off.  (Id.)            

IV.  TARGET ANNOUNCEMENT OF DEMAND DECLINE                                
On May 18, 2022, Target announced its Q1 results.  (Id. ¶ 116.)  According to 
Plaintiffs,  that  announcement  revealed  that  Target’s  net  profits  were  down  52%,  its 
operating margin was “well below expectations, driven primarily by gross margin pressure 
reflecting actions to reduce excess inventory,” and that gross margin had dropped to 25.7% 
compared to 30.0% in the same quarter 2021, which “reflected higher markdown rates.”  

(Id.)  Hennington stated that,                                            
     as supply grew and demand shifted away from bigger, bulkier     
     products like furniture, TVs and more, we needed to make        
     difficult trade-off decisions . . . .  To preserve the quality of on-
     shelf presentations and support the guest experience, we chose  
     [to  make  room  for  fast-growing  categories],  leading  to   
     incremental markdowns that reduced our gross margin.            
(Id. ¶ 120 (emphasis omitted).)  Cornell stated that much of the excess inventory was in 
“bulky” categories such as “kitchen appliances, TVs and outdoor furniture”—products 
within Target’s HHGs categories, which the CWs and Target employees had spoken about.  
(Id. ¶ 118.)  On this news, Target’s stock price declined $53.67 per share, or nearly 25%, 
from a closing price of $215.28 per share on May 17, 2022, to close at $161.61 per share 
on May 18, 2022. (Id. ¶ 124.)                                             
V.   THIS ACTION                                                          
Plaintiffs commenced this action in March 2023.  (Doc. No. 1.)  In their Amended 
Complaint, Plaintiffs assert two claims.  (See Am. Compl.)  Count I is a claim for securities 
fraud  under  Section  10(b)  of  the  Exchange  Act,  15  U.S.C.  § 78j(b),  and  the  SEC’s 
implementing Regulation, Rule 10b-5, 
17 C.F.R. § 240
.10b-5, against all Defendants.  (Id. 

¶¶ 170–80.)  Count II is a claim of controlling-person liability under Section 20(a) of the 
Exchange Act against the Individual Defendants.  (Id. ¶¶ 181–85.)         
                      DISCUSSION                                     
Defendants move to dismiss the Amended Complaint pursuant to Federal Rule of 
Civil Procedure 12(b)(6).  A complaint must present “a short and plain statement of the 

claim showing that the pleader is entitled to relief.”  Fed. R. Civ. P. 8(a)(2); see also Braden 
v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009).  To survive a motion to dismiss 
under Rule 12(b)(6), the complaint “must contain sufficient factual material, accepted as 
true, to ‘state a claim to relief that is plausible on its face.’”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009) (quoting Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 570
 (2007)).  A 
pleading  has  facial  plausibility  when  its  allegations  “allow[]  the  court  to  draw  the 

reasonable inference that the defendant is liable for the misconduct alleged.”  
Id.
  In this 
analysis, the Court construes the allegations and draws inferences from them in the light 
most favorable to the plaintiff.  Park Irmat Drug Corp. v. Express Scripts Holding Co., 
911 F.3d 505, 512
 (8th Cir. 2018).                                            
Defendants argue that Plaintiffs’ allegations do not satisfy the heightened pleading 

standards set forth in the Private Securities Litigation Reform Act (PSLRA), 15 U.S.C. 
§ 78u-4(b, which applies to their claims.  (Doc. No. 81.)  As discussed below, the Court 
agrees.                                                                   
I.   FAILURE TO ADEQUATELY ALLEGE FALSITY IN COUNT I                      
Section 10(b) of the Exchange Act makes it unlawful “[t]o use or employ, in 

connection with the purchase or sale of any security . . . any manipulative or deceptive 
device or contrivance in contravention of such rules and regulations as the [SEC] may 
prescribe.”  15 U.S.C. § 78j(b).  Rule 10b-5 also makes it unlawful to, among other things, 
“make any untrue statement of a material fact or to omit to state a material fact necessary 
in order to make the statements made, in the light of the circumstances under which they 
were made, not misleading.”  
17 C.F.R. § 240
.10b-5(b).  Together, Section 10(b) and Rule 

10b-5 create a private cause of action for fraud.  See Halliburton Co. v. Erica P. John Fund, 
Inc., 
573 U.S. 258
, 267 (2014).  A claim for securities fraud under Section 10(b) and Rule 
10b-5 has the following six elements: “(1) a material misrepresentation or omission by the 
defendant; (2) scienter; (3) a connection between the misrepresentation or omission and 
the purchase or sale of a security; (4) reliance upon the misrepresentation or omission; 

(5) economic loss; and (6) loss causation.”  
Id.
 (quotation omitted).     
In addition to the Iqbal/Twombly pleading standard, when a plaintiff has alleged 
securities  fraud  claims,  the  complaint  is  also  subject  to  the  heightened  pleading 
requirements of the PSLRA, which incorporates the standards of and supersedes reliance 
on Federal Rule of Civil Procedure 9(b).  In re Navarre Corp. Sec. Litig., 
299 F.3d 735, 742
 (8th Cir. 2002); see Fed. R. Civ. P. 9(b) (setting forth that a party alleging fraud must 
“state with particularity the circumstances constituting fraud” but that “[m]alice, intent, 
knowledge, and other conditions of a person’s mind may be alleged generally”).  The 
PSLRA is distinct from Rule 9(b) because it requires that falsity and scienter be pleaded 
with particularity.  Navarre, 
299 F.3d at 742
.                            

Defendants argue that Plaintiffs’ allegations do not satisfy the heightened PSLRA 
standard in any of the elements of their claim.  The Court begins and ends its analysis of 
Count I with the falsity element.7  (Doc. No. 83 at 12–37.)  Under the PSLRA, the 
complaint must “specify each false statement or misleading omission and explain why the 
omission was misleading.”  15 U.S.C. § 78u-4(b)(1).  The complaint must set forth the 
“who, what, when, where and how of the misleading statements or omissions,” In re 2007 

Novastar Fin. Inc., Sec. Litig., 
579 F.3d 878, 882
 (8th Cir. 2009) (quotation omitted), and 
“indicate why the alleged misstatements would have been false or misleading at the several 
points in time in which it is alleged they were made.”  In re Hutchinson Tech., Inc. Sec. 
Litig., 
536 F.3d 952
, 958–59 (8th Cir. 2008) (quotation omitted).  Defendants argue that 
there are “universal defects” with Plaintiffs’ falsity allegations, namely that Plaintiffs have 

failed to allege the basis for the CWs’ knowledge and that some of the CWs’ statements 
are consistent with Target’s statements, while others are contradicted by Target’s public 
disclosures.  (Doc. No. 83 at 23–30.)  In addition, Defendants argue that the alleged 
misstatements  are  nonactionable  for  independent  reasons,  which  vary  based  on  the 
category of statement at issue.  (Id. at 13, 30.)                         




7 In light of the Court’s decision that Plaintiffs have failed to plead falsity, the Court need 
not reach the question of whether Plaintiffs have adequately pleaded scienter.   
A.   Universal Defects                                               
Allegations based on confidential witness accounts in securities-fraud actions are 

distinct from other factual allegations contained in a complaint (which courts must accept 
as true on a motion to dismiss), and courts view them with skepticism.  See Minneapolis 
Firefighters’ Relief Ass’n v. MEMC Elec. Materials, Inc., 
641 F.3d 1023, 1030
 (8th Cir. 
2011) (disregarding plaintiff’s reliance on allegations of confidential sources and affirming 
dismissal for failure to state a securities-fraud claim); see also Trs. of Welfare & Pension 
Funds of Loc. 464A - Pension Fund v. Medtronic PLC, No. 22-CV-2197 (KMM/JFD), 

2024 WL 1332262
, at *30 (D. Minn. Mar. 28, 2024) (granting motion to dismiss for failure 
to state a securities fraud claim and noting that courts “treat allegations in a complaint 
based  on  the  accounts  of  confidential  witnesses  with  skepticism”);  Shoemaker  v. 
Cardiovascular Sys. Inc., 
300 F. Supp. 3d 1046, 1055
 (D. Minn. 2018) (granting motion to 
dismiss for failure to state a securities fraud claim and noting that “courts are not required 

to wholly accept as true statements from a confidential witness”).  When determining 
whether a plaintiff’s allegations satisfy the PLSRA’s heightened pleading standard, courts 
consider, among other things, whether the complaint contains allegations that support a 
confidential witness’s basis of knowledge.  In re NVE Corp. Sec. Litig., 
551 F. Supp. 2d 871, 881
 (D. Minn. 2007), aff’d, 
527 F.3d 749
 (8th Cir. 2008).            

Dismissal is proper where the plaintiff fails to adequately allege the confidential 
witness’s basis of knowledge and the confidential witness’s statement is the only allegation 
supporting the alleged misrepresentation.  See, e.g., In re Hutchinson Tech., 536 F.3d at 
959–60  (affirming  dismissal  for  failure  to  state  a  securities  fraud  claim  because  the 
complaint  lacked  “any  allegations  showing  the  basis  of”  the  confidential  witness’s 
knowledge,  and  the  confidential  witness  “provided  the  only  basis  for”  the  alleged 

misrepresentation); Pound v. Stereotaxis, Inc., 
8 F. Supp. 3d 1157, 1166
 (E.D. Mo. 2014) 
(noting same).                                                            
The allegations in the Amended Complaint do not satisfy the PSLRA’s heightened 
pleading requirement because they fail to adequately set forth any of the three CWs’ basis 
for  knowing  facts  that  support  the  heart  of  the  alleged  omission:  that  Target  had 
“abandoned its customer-focused purchasing strategy” in favor of “indiscriminately buying 

large quantities of inventory” that consumers did not want, particularly HHGs.  (Am. 
Compl. ¶ 39.)  Plaintiffs fail to allege facts to support the notion that the CWs had personal 
knowledge of Target’s inventory procurement processes (e.g., what Target’s consumer 
data showed, how the data factored into Target’s inventory procurement, or how the data 
was inconsistent with Targets actions).  Plaintiffs have also failed to allege how any of the 

CWs knew that Defendants had abandoned Target’s inventory procurement policy in favor 
of intentionally ordering inventory without regard to consumer demand.  For instance, there 
are no allegations that any of the CWs were involved at the merchandise-procurement stage 
or spoke with anybody involved at that stage who shared knowledge of an intentional shift 
in the inventory-procurement policy.  Additionally, there are no allegations to suggest any 

of the CWs analyzed Target’s companywide sales or demand, knew customer-purchasing 
patterns across Target’s business, let alone what merchandise Target was purchasing and 
when.  Rather, Plaintiffs allege that the CWs had knowledge of Target’s inventory after it 
was procured, namely that they observed inventory levels increasing after the fact, which 
is not enough to survive a motion to dismiss.  See In re Hutchinson Tech. Inc. Sec. Litig., 
502 F. Supp. 2d 884, 895
 (D. Minn. 2007) (concluding that CW’s observation that returns 

had decreased did not support allegation that the company’s return allowances were 
inadequate), aff’d, 
536 F.3d 952
.  Moreover, the CWs’ observations were consistent with 
Target’s public statements that it was preordering merchandise and investing in increased 
inventory.  (See Doc. No. 84, Ex. L at 31.)  Target’s audited financial statements show that 
consumer demand for HHGs was consistently increasing throughout 2021, on top of record 
increases in 2020.  (Id., Ex. K.)                                         

Thus,  drawing  all  reasonable  inferences  in  Plaintiffs’  favor,  the  allegations 
contained in the Amended Complaint fail to adequately allege falsity, in part, because they 
do not set forth facts demonstrating the CWs’ basis for knowing the alleged omission.   
B.   Independent Grounds                                             
Defendants group the twenty alleged misstatements into six categories: (1) demand 

warnings;  (2)  insight  statements;  (3)  investment  statements;  (4)  flow  statements;  
(5) historic statements; and (6) markdown projections.  Defendants then contend that the 
six categories of statements constitute forward-looking statements, statements of corporate 
optimism, and opinion statements, which are nonactionable under the PSLRA.  (Doc. No. 
83 at 35–47.)  The Court agrees.                                          

Under  the  PSLRA’s  “safe-harbor”  provisions,  a  defendant’s  forward-looking 
statements  are  nonactionable  if  they  are  accompanied  by  “meaningful  cautionary 
statements,” are “immaterial,” or made without actual knowledge of falsity.  15 U.S.C. 
§ 78u-5(c); see also Julianello v. K-V Pharm. Co., 
791 F.3d 915
, 920–21 (8th Cir. 2015).  
Forward-looking statements include the following types of statements: “(1) projections of 
revenues  or  other  financial  items,  (2)  statements  of  plans  and  objectives  for  future 

operations, and (3) statements of the assumptions underlying the previous two categories.”  
K-V Pharm, 
791 F.3d at 921
 (citing 15 U.S.C. § 78u-5(i)(1)).  “In determining whether a 
statement  is  truly  forward-looking,  the  determinative  factor  is  not  the  tense  of  the 
statement; instead, the key is whether its truth or falsity is discernible only after it is made.”  
Id. (quotation omitted).  In addition, a statement that accurately reports past events or 
historic performance cannot support a securities fraud action.  In re Marion Merrell Dow 

Inc., Sec. Litig. II, No. 93-0251-CV-W-6, 
1994 WL 396187
, at *3–4 (W.D. Mo. July 18, 
1994); see also In re Medtronic Inc., Sec. Litig., 
618 F. Supp. 2d 1016, 1031
 (D. Minn. 
2009) (concluding that company’s public statements were nonactionable because they 
reported accurate historical financial information).                      
The Court considers each of the twenty statements, by category, to determine 

whether they are actionable under the PSLRA.                              
     i.   Demand Warnings                                            
The first category of allegedly misleading statements concerns Statements 10 and 
20, warnings about demand that Target included in its Form 10-K and Form 10-Q filings 
with the SEC.  (Am. Compl. ¶¶ 94, 114.)  These filings disclosed the following three risks 

that could occur if Target did not obtain accurate and relevant data on and anticipate and 
respond  quickly  to  changing  consumer  preferences:  (1)  lost  sales,  (2)  spoilage,  and 
(3) increased  inventory  markdowns  that  could  adversely  affect  Target’s  results  of 
operation.  (Id.)  According to Plaintiffs, these statements were  materially false and 
misleading because Defendants had stopped procuring inventory based on consumer data 
and  insights,  resulting  in  unwanted  inventory  that  Target  could  not  sell,  and  that 

necessitated large discounts and corresponding write-offs.  The Court disagrees and finds 
that the statements are nonactionable for the following two reasons.      
First, Plaintiffs have failed to plausibly allege that the statements were made “with 
actual  knowledge  .  .  .  that  the  statement[s] w[ere]  false  or  misleading.”    15  U.S.C. 
§ 78u‑5(c)(1)(B).  The Amended Complaint contains no allegation that when Defendants 
made these statements on November 24, 2021, and March 9, 2022, they knew that lost 

sales, spoilage, and increased inventory markdowns had already occurred.  Trs. of Welfare, 
2024 WL 1332262
, at *15 (finding forward-looking statements nonactionable under the 
PSLRA’s safe-harbor provisions where plaintiffs did not plausibly allege that at the times 
defendants made the forward-looking statements, they knew that the potential risk about 
which they cautioned had already been realized).                          

Second,  the  allegations  do  not  support  an  inference  that  the  statements  were 
materially false.  15 U.S.C. § 78u-5(c)(1)(A) (stating the persons “shall not be liable with 
respect to any forward-looking statement . . . to the extent that . . . the forward-looking 
statement is . . . immaterial”).  The most support Plaintiffs seem to offer for such an 
allegation comes from CW-3’s statement that by June 2021, Target corporate headquarters 

had directed increasing markdowns of certain overstocked products.  (Am. Compl. ¶ 72.)  
However, these statements say nothing of magnitude or degree; without more, they cannot 
support an inference that the unqualified markdowns would materially harm Target’s 
operations.  Moreover, audited financial statements show that sales of HHGs increased 
throughout 2021.  (See Doc. No. 84, Ex. K.)  Specifically, hardline sales in 2021 increased 
48% from 2019 and 12% from 2020, and home goods increased 40% from 2019 and 11% 

from 2020.  (Id.)  Given this increase, the Court cannot draw any inference that the demand 
statements were materially false and misleading.                          
     ii.  Insight Statements                                         
The second category of allegedly misleading statements concerns Statements 1 and 
12, two statements made during Target’s Q3 and Q4 2021 earnings calls.  (Am. Compl. 
¶¶ 81, 98.)  According to Plaintiffs, these insight statements were materially false and 

misleading  because  as  of  June  2021,  Target  was  not  procuring  inventory  based  on 
consumer demand.  The Court disagrees and finds that the statements are nonactionable 
optimistic rhetoric.                                                      
A statement is nonactionable, under Section 10(b), if “a reasonable investor could 
not have been swayed by the statement.”  City of Plantation Police Officers Pension Fund 

v. Meredith Corp., 
16 F.4th 553, 556
 (8th Cir. 2021) (quotation omitted).  “Vague or 
optimistic rhetoric—sometimes called corporate ‘puffery’—falls into this category.”  
Id.
 
(quotation omitted).  The insight statements at issue here reference Target’s continuous 
evaluation of its guests’ mindset, “which serves as a North Star for all [its] strategies and 
decisions,” as well as the fact that Target listens “to the everchanging wants and needs of 

[its] guests.”  (Am. Compl. ¶¶ 81, 98.)  Such statements constitute quintessential examples 
of nonactionable corporate puffery.  Meredith, 
16 F.4th at 557
 (deeming references to 
“proven strategies” inactionable corporate puffery); see also Kusnier v. Virgin Galactic 
Holdings, Inc., 
639 F. Supp. 3d 350
, 374 (E.D.N.Y. 2022) (concluding that defendant’s 
statement of “uncompromising commitment to . . . customer satisfaction” was “pure 
puffery”); In re CenturyLink Sales Pracs. & Sec. Litig., 
403 F. Supp. 3d 712
, 727 (D. Minn. 

2019) (noting that “in many instances, statements about meeting customer needs could be 
puffery” but not where it is alleged that defendant’s financial performance stemmed, in 
material part, from fraud on customers); City of Warren Police & Fire Ret. Sys. v. Foot 
Locker, Inc., 
412 F. Supp. 3d 206
, 221 (E.D.N.Y 2019) (interpreting statements that 
defendant “understands what its customers want and has a connectivity with its consumer” 
as “plainly puffery” (quotations omitted)).  Thus, no reasonable investor could have been 

swayed by Defendants’ vague, optimistic insight statements.               
     iii.  Investment Statements                                     
The third category of allegedly misleading statements concerns Statements 3, 5, 6, 
16, and 17, which comprise five statements made during the Q3 2021 earnings call, the 
question-and-answer session that immediately followed, the Bloomberg interview, and in 

the Form 10-K.  (Am. Compl. ¶¶ 81, 84, 86, 105, 108.)  The Defendants’ statements express 
generic  optimism  about  Target’s  inventory  investments,  describing  its  inventory  as 
“healthy” and “well-positioned,” and stating that they felt good about it.  (Id. ¶¶ 81, 84, 86, 
105.)  The Form 10-K also described how Target carefully plans seasonal inventory levels 
to  minimize  markdowns  and  achieve  effective  inventory  management.    (Id.  ¶ 108.)  

According to Plaintiffs, these statements were materially false and misleading because 
Target  had  no  basis  to  view  its  inventory  positively  after  experiencing  overstocked 
inventory as a result—Plaintiffs allege—of no longer considering consumer demand when 
procuring inventory.  Again, the Court disagrees, concluding that these statements are also 
nonactionable corporate puffery.                                          

Previous  courts  have  reached  the  same  conclusion concerning  nearly  identical 
positive inventory characterizations.  See, e.g., Trs. of Welfare, 
2024 WL 1332262
, at *30 
(finding defendant’s statement that they “felt really good about the pipeline” for products 
was an inactionable statement of optimism and opinion (quotation omitted)); In re Target 
Corp. Sec. Litig., 
955 F.3d 738
, 743 n.2 (8th Cir. 2020) (finding defendant’s statement that 
they “feel really good about where we are today” was nonactionable puffery); In re 

Hutchinson  Tech.,  
536 F.3d at 960
  (affirming  district  court’s  determination  that 
defendant’s statement that it was “well-positioned” was too vague); see also Robeco Cap. 
Growth Funds SICAV – Robeco Glob. Consumer Trends v. Peloton Interactive, Inc., No. 
21-CV-9582  (ALC)(OTW),  
2024 WL 4362747
,  at  *12  (S.D.N.Y.  Sept.  30,  2024) 
(concluding  that  defendant’s  forward-looking  statement  about  its  “healthy”  inventory 

heading into a busy time of year was “precisely the type of vague expressions of optimism” 
that courts dismiss).  Moreover, the context of the investment statements at issue here 
would have made clear to a reasonable investor that the health of Target’s inventory was 
relative to the persistent inventory shortages resulting from the unprecedented COVID-19 
pandemic and its effect on the global economy.  See In re K-tel Int’l, Inc. Sec. Litig., 
300 F.3d 881, 897
  (8th  Cir.  2002)  (“[I]f  no  reasonable  investor  could  conclude  public 
statements, taken together and in context were misleading, then the issue is appropriately 
resolved as a matter of law.”)  Thus, the investment statements cannot support an actionable 
securities fraud claim.                                                   
     iv.  Flow Statements                                            
The next category of allegedly misleading statements concerns Statements 2, 4, and 

15, three statements made during Target’s Q3 and Q4 2021 earnings calls concerning the 
flow of inventory.  (Am. Compl. ¶¶ 81, 82, 103.)  The Defendants’ statements describe 
Target’s efforts to move the right inventory “to the right place at the right time” (id. ¶¶ 81, 
82), as well as how “[s]peed and flow of inventory is the key to the whole game” and “there 
was a lot of headroom for growth” because inventory was constantly moving through 
Target’s “largest stores.”  (Id. ¶ 103.)  Again, Plaintiffs argue these statements were 

materially  false  and  misleading  because  Target  had  no  basis  to  view  its  inventory 
positively.  The Court disagrees and finds the flow statements are nonactionable for the 
following two reasons.                                                    
First,  the  mere  allegation  that  Target  procured  inventory  without  regard  for 
consumer demand does not necessary establish the falsity of Target’s statement that it was 

trying to get the right inventory to the right place at the right time.  See Foot Locker, 412 
F. Supp. 3d at 224 (noting that confidential witnesses’ statements that retailer bought “large 
quantities of undesirable merchandise in order to obtain desirable merchandise” did not 
undercut the retailer’s statements that it was “try[ing] to get what it thought was the 
appropriate amount for its stores” or “working to improve allocation to get the right product 

to the right place, right time” (quotation omitted)).  Nor does it necessarily mean that 
Target’s other flow statements were false.                                
Second, as with the insight and investment statements discussed above, the flow 
statements are also examples of vague, optimistic rhetoric that constitutes nonactionable 
puffery.  See U.S. Bank Nat’l Ass’n v. PHL Variable Ins. Co., No 12-CV-6811 (CM)(JCF), 
2013 WL 791462
, at *6 (S.D.N.Y. Mar. 5, 2013) (“Where a representation is subject to 

varying interpretations depending upon varying standards different persons use, classic 
puffery is involved.” (quotation omitted)); Gammel v. Hewlett-Packard Co., 
905 F. Supp. 2d 1052
 (C.D. Cal. 2012) (concluding that alleged misstatements that corporation would 
“draw on its deep executive bench to position the right leaders in the right roles to 
accelerate  the  long-term  growth”  was  nonactionable  puffery).    Therefore,  the  flow 
statements are nonactionable.                                             

     v.   Historic Statements                                        
The next category of allegedly misleading statements concerns Statements 7, 8, 9, 
11, 18, and 19, which comprise six statements made in Target’s Form 10-Q, press release, 
Q4 2021 earnings call, and Form 10-K.  (Am. Compl. ¶¶ 88, 90, 92, 96, 110, 112.)  These 
statements report on  Target’s past  financial and operating results, gross margin rate, 

inventory position, and certain company actions.  (See id.)  According to Plaintiffs, these 
statements were materially false and misleading because they misled investors as to the 
likelihood of future markdowns.  (Id. ¶¶ 91, 97, 111.)  The Court disagrees and finds these 
statements are nonactionable because they are reports of past performance or events and 
the Amended Complaint contains no allegations that the historic statements are false or 

inaccurate.  See In re Marion Merrell Dow, 
1994 WL 396187
, at *3–4 (listing cases and 
noting that “statements pertaining to past performance not alleged to be inaccurate are 
clearly not materially misleading”); see also In re Medtronic, 
618 F. Supp. 2d at 1031
 
(dismissing for failure to state a securities fraud claim because the complaint made no 
allegations that the statements at issue, which concerned past sales and economic success, 
were inaccurate).                                                         

     vi.  Markdown Projections                                       
The final category of allegedly misleading statements concerns Statements 13 and 
14, which  comprise  two  statements  made during  the  Q4  2021 earnings  call  and  the 
question-and-answer session immediately following that call.  (Am. Compl. ¶¶ 100, 101.)  
The Defendants’ statements relate to their projections for a “small increase in markdown 
rates.”  (Id. ¶ 100.)  According to Plaintiffs, these statements were materially false and 

misleading  because  Defendants  knew  that  HHG  inventory  would  need  “significant 
markdowns and write-offs the immediately following quarter,” yet understated their extent.  
(Id. ¶ 102.)  The Court disagrees.                                        
The  markdown  statements  are  nonactionable  because  Plaintiffs  have  failed  to 
plausibly  allege  that  at  the  time  the  statements  were  made  Defendants  had  “actual 

knowledge . . . that the statement[s] w[ere] false or misleading.”  15 U.S.C. § 78u-
5(c)(1)(B(ii)(II).  Specifically, Plaintiffs have failed to allege facts showing that Defendants 
knew—at the time these statements were made—that demand would rapidly change later 
that month, necessitating additional markdowns beyond those contemplated at that time.  
See In re Target Sec. Litig., 
275 F. Supp. 3d 1063, 1071
 (D. Minn. 2017) (“[M]erely 

pleading that the prediction must have been false mid-year because it conflicts with year-
end facts [is] an unsatisfactory explanation for ‘why’ the mid-year statement was false 
when made.”); In re Leapfrog Enter., Inc. Sec. Litig., 
200 F. Supp. 3d 987, 1005
 (N.D. Cal. 
2016) (finding that just because inventory did not move as quickly as defendants projected 
it would did not mean projections were false when made).                  

In  sum,  drawing  all  reasonable  inferences  in  Plaintiffs’  favor,  the  Court  also 
concludes that the allegations contained in the Amended Complaint fail to adequately 
allege falsity because the statements identified by Plaintiffs are protected by the PSLRA’s 
safe-harbor provisions, namely, that they are material and that the Defendants had actual 
knowledge that the statements were false at the time they were made.  Additionally, many 
of the statements are nonactionable statements of corporate optimism, opinion statements, 

or uncontested statements of past performance.                            
For these reasons, the Court will dismiss Count I.                   
II.  COUNT II                                                             
Because Plaintiffs have failed to adequately allege their Section 10(b) and Rule 10b-
5 claim, the claim under Section 20(a) also fails as a matter of law.  Lustgraaf v. Behrens, 

619 F.3d 867, 874
 (8th Cir. 2010) (“The plain language of the control-person statute 
dictates that, absent a primary violation, a claim for control-person liability must fail.”).  
Therefore, the Court will also dismiss Count II.                          
III.  FORM OF DISMISSAL                                                   
“[C]ourts  ultimately  have  discretion  to  decide  between  a  with-prejudice  and 

without-prejudice dismissal.”  Miles v. Simmons Univ., 
514 F. Supp. 3d 1070
, 1080 (D. 
Minn.  2021).    Dismissal  with  prejudice  is  appropriate  “when  a  plaintiff  has  shown 
persistent pleading failures despite one or more opportunities to amend.”  
Id.
 (quotation 
omitted).  However, “when a plaintiff’s claims might conceivably be repleaded with 
success, . . . dismissal  without  prejudice  may  be  justified.”    
Id.
  (quotations  omitted).  
Plaintiffs state that they intend to file a motion for leave to amend, pursuant to D. Minn. 

Local Rule 15.1(b), if the Court dismisses their complaint in its entirety.  (Doc. No. 91 at 
73 n.40.)                                                                 
Before the present motion was filed, Plaintiffs requested, and were granted, an 
extension to file their amended complaint.  (Doc. Nos. 60, 65, 70.)  Plaintiffs also could 
have filed a motion for leave to amend, pursuant to Rule 15.1(b), upon reviewing the 
arguments Defendants raised in their motion to dismiss, but they chose to stand by the 

Amended Complaint in its present form.  Moreover, the Court concludes that the factual 
deficiencies here cannot conceivably be cured.  Therefore, the Court will not entertain a 
motion brought pursuant to Rule 15.1(b), and this action will be dismissed with prejudice.    

ORDER

Based on the foregoing, and on all of the files, records, and proceedings herein, 

IT IS HEREBY ORDERED THAT:                                                
1.   Defendants Target Corporation’s, Brian C. Cornell’s, Michael J. Fiddelke’s, 
     A. Christina Hennington’s, and John J. Mulligan’s Motion to Dismiss (Doc. 
     No. 81) is GRANTED; and                                         

2.   The  Amended  Complaint  (Doc.  No.  70)  is  DISMISSED  WITH   
     PREJUDICE.                                                      

LET JUDGMENT BE ENTERED ACCORDINGLY.                                 


Dated:  November 15, 2024               /s/ Jeffrey M. Bryan              
                                   Judge Jeffrey M. Bryan            
                                   United States District Court      

Reference

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