Harman International Industries, Inc. v. Arkansas Public Employees Retirement System

(1) Whether, under the Private Securities Litigation Reform Act, a purported misrepresentation is sufficient to preclude protection under the safe harbor for forward-looking statements; (2) whether, under the Act, courts can consider an issuer's alleged knowledge to determine whether cautionary statements are "meaningful"; and (3) whether a vague and immeasurable characterization of results, such as sales were "very strong," is immaterial puffery as a matter of law.