... arguments for dismissal of such claims. Within six months of the Supreme Court’s decision, Janus has already led to a variety of applications in the district courts. It will take time for appeals ... holding out of context.” Janus involved a different factual scenario involving distinct legal entities, whereas the EVP was an officer of Merck at the time of the statements, signed SEC forms, and ... creation of misstatements in marketing materials.22 The Ramifications of Janus: Alternative Theories of Liability Will Proliferate In the wake of Janus, defendants will continue to advocate for...