Sarria v. TELUS International (Cda) Inc. — Entry #39: REPLY MEMORANDUM OF LAW in Support re: 35 MOTION to Dismiss the Amended Class Action Complaint for Violations of the Federal Securities Laws

Case 1:25-cv-00889-VM         Document 39    Filed 01/14/26   Page 1 of 18


                          UNITED STATES DISTRICT COURT
                         SOUTHERN DISTRICT OF NEW YORK


JOSÉ LUIS CERÓN SARRIA, Individually
and on Behalf of All Others Similarly Situated,
                                   Plaintiff,

 v.                                                Case No. 1:25-CV-00889-VM

TELUS INTERNATIONAL (CDA) INC.,
JEFFREY PURITT, VANESSA KANU,
GOPI CHANDE, and MICHAEL RINGMAN,
                                   Defendants.


                   REPLY IN SUPPORT OF DEFENDANTS’
        MOTION TO DISMISS THE AMENDED CLASS ACTION COMPLAINT
           FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS


          Case 1:25-cv-00889-VM                        Document 39               Filed 01/14/26              Page 2 of 18


                                                  TABLE OF CONTENTS

                                                                                                                                     Page

ARGUMENT ...................................................................................................................................1
I.        The Complaint Fails to Plead That Any Challenged Statement Is False .............................1
II.       Plaintiff Fails to Plead a Strong Inference of Scienter .........................................................7
III.      Plaintiff Fails to Plead Loss Causation ..............................................................................11
CONCLUSION ..............................................................................................................................12


                                                                     ii


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                                             TABLE OF AUTHORITIES

                                                                                                                          Page(s)

Cases

Abramson v. Newlink Genetics Corp.,
   965 F.3d 165 (2d Cir. 2020).....................................................................................................11

In re Alstom SA Sec. Litig.,
    406 F. Supp. 2d 433 (S.D.N.Y. 2005)......................................................................................10

In re Amarin Corp. PLC Sec. Litig.,
    2016 WL 1644623 (D.N.J. Apr. 26, 2016) ................................................................................3

In re Avon Securities Litigation,
    2019 WL 6115349 (S.D.N.Y. Nov. 18, 2019) ...........................................................................8

Boston Ret. Sys. v. Alexion Pharms., Inc.,
   556 F. Supp. 3d 100 (D. Conn. 2021) ......................................................................................11

City of Omaha Police & Fire Ret. Sys. v. Evoqua Water Techs. Corp.,
    450 F. Supp. 3d 379 (S.D.N.Y. 2020)........................................................................................2

City of Sterling Heights Police & Fire Ret. Sys. v. Vodafone Grp. Pub. Co.,
    655 F. Supp. 2d 262 (S.D.N.Y. 2009)........................................................................................9

Colbert v. Rio Tinto PLC,
   824 F. App’x 5 (2d Cir. 2020) ...................................................................................................8

In re DNTW Chartered Accountants Sec. Litig.,
    172 F. Supp. 3d 675 (S.D.N.Y.).................................................................................................9

In re Facebook, Inc. IPO Sec. & Deriv. Litig.,
    986 F. Supp. 2d 487 (S.D.N.Y. 2013)........................................................................................7

In re GigaCloud Tech. Inc. Sec. Litig.,
    2025 WL 307378 (S.D.N.Y. Jan. 27, 2025) ..............................................................................2

Gray v. Wesco Aircraft Holdings, Inc.,
   454 F. Supp. 3d 366 (S.D.N.Y. 2020)........................................................................................5

Hampshire Equity Partners II, L.P. v. Teradyne, Inc.,
  2005 WL 736217 (S.D.N.Y. Mar. 30, 2005) .............................................................................9

In Carmignac Gestion, S.A. v. Perrigo Co. PLC,
    2019 WL 3451523 (D.N.J. July 31, 2019) .................................................................................7


                                                                 iii


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Kuriakose v. Fed. Home Loan Mortg. Corp.,
   897 F. Supp. 2d 168 (S.D.N.Y. 2012)........................................................................................8

In re Nielsen Holdings PLC Sec. Litig.,
    510 F. Supp. 3d 217 (S.D.N.Y. 2021)......................................................................................10

In Re Philip Morris Int’l Inc. Sec. Litig.,
    89 F.4th 408 (2d Cir. 2023) .......................................................................................................6

Emps.’ Ret. Sys. v. Blanford,
  794 F.3d 297 (2d Cir. 2015).......................................................................................................9

Stadium Cap. LLC v. Co-Diagnostics, Inc.,
   2024 WL 456745 (S.D.N.Y. Feb. 5, 2024) ................................................................................9

In re Stemline Therapeutics, Inc. Sec. Litig.,
    313 F. Supp. 3d 543 (S.D.N.Y. 2018)........................................................................................3

In re STMicroelectronics N.V. Sec. Litig.,
    2025 WL 2644241 (S.D.N.Y. Sept. 15, 2025) .........................................................................10

In re Synchrony Fin. Sec. Litig.,
    2022 WL 427499 (D. Conn. Feb. 11, 2022) ..............................................................................8

Teamsters Loc. 445 Freight Div. Pension Fund v. Dynex Cap. Inc.,
   531 F.3d 190 (2d Cir. 2008).....................................................................................................10

In re Turquoise Hill Res. Ltd. Sec. Litig.,
    625 F. Supp. 3d 164 (S.D.N.Y. 2022)......................................................................................10

In re United States Oil Fund, LP Sec. Litig.,
    2025 WL 2771445 (S.D.N.Y. Sept. 29, 2025) ...........................................................................2

in re Vivendi Universal, S.A. Sec. Litig.,
    765 F. Supp. 2d 512 (S.D.N.Y. 2011)........................................................................................8

Yannes v. SCWorx Corp.,
   2021 WL 2555437 (S.D.N.Y. June 21, 2021) .........................................................................10

Statutes

Private Securities Litigation Reform Act ...................................................................................5, 10


                                                                  iv


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       Plaintiff argues that TI is an AI company that seized on AI hype to boost its share price,

but never developed a single viable AI product or service. That accusation is entirely unsupported

by pleaded facts, as the Opposition lays bare:

       No False Statement: Like the Complaint, the Opposition fails to identify any AI product

or service that TI falsely claimed to have. Plaintiff relies on CWs and supposed “admissions,” but

neither support his fictional proclamation that TI falsely claimed any AI capabilities. To the

contrary, Plaintiff admits that TI’s four business lines generated millions in revenue from selling

AI-related capabilities, and concedes through CWs that AI-related capabilities did exist.

       No Scienter: Plaintiff concedes that Defendants had no motive to lie. And Plaintiff cites

no facts showing that Puritt, Kanu, Chande and Ringman—the senior executives who purportedly

engaged in fraud—knowingly engaged in misconduct. Indeed, the Individual Defendants are

barely mentioned in the Opposition. Plaintiff comes nowhere near the required “strong inference”

that any Defendant acted with the required fraudulent intent.

       Loss Causation:        Plaintiff admits that TI’s stock dropped when TI announced

disappointing financial results. Since Plaintiff cannot identify any corrective disclosure revealing

the so-called “truth” that TI lacked AI capabilities, loss causation is not pleaded.

                                           ARGUMENT

I.     The Complaint Fails to Plead That Any Challenged Statement Is False

       Plaintiff argues the Challenged Statements are false because TI falsely claimed to have AI

capabilities. But Plaintiff relies only on (1) four CWs who do not identify any AI capability that

TI falsely claimed to have, and (2) purported “admissions” that TI had “only” AI pilots, which no

Defendant made.

       CWs: Opposite to identifying any specific AI product or service that TI falsely claimed to

have, every CW admits that TI developed and sold AI capabilities: CW-1 “contributed to


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automation and AI initiatives” (¶30); CW-2 “sold WillowTree/Telus’ products and services,

including AI, to clients” (Opp. 11); CW-3 “developed apps and software programs and, thus, knew

about WillowTree/Telus’ AI capabilities” (id.); and CW-4 “train[ed] WillowTree employees in

AI” (Opp. 11) and admits that TI developed Fuel iX, an AI-product (¶118). The Court should

reject Plaintiff’s unsupported and internally-inconsistent CW arguments that TI lacked AI

capabilities. See In re United States Oil Fund, LP Sec. Litig., 2025 WL 2771445, at *15 (S.D.N.Y.

Sept. 29, 2025) (“a court is neither obligated to reconcile nor accept” inconsistent and contradictory

allegations).

       The CW arguments also fail because the CWs had no company-wide visibility into AI

business and strategy. (Br. 10-12.) Plaintiff concedes CW allegations may be credited only where

they “support the probability that a person in the position occupied by the source would possess

the information alleged.” (Opp. 10.) Three CWs worked in one business line, WillowTree—

which the CWs admit did have AI capabilities—and another did not even work at TI.1 (Br. 11-

12.) Unlike In re GigaCloud Tech. Inc. Sec. Litig., 2025 WL 307378 (S.D.N.Y. Jan. 27, 2025),

the CWs here did not work in relevant positions, nor do they provide detailed descriptions showing

the absence of AI. Id. at *7-*8. In sum, the CWs offer no support.

       Supposed “Admissions”: Plaintiff also relies on Defendants’ supposed “admissions” that

TI “only” offered “pilot” AI products. (Br. 12-13.) But Plaintiff injected the word “only;” TI

never said that its AI offerings were limited “only” to pilots. (Id.; Ex. 16 at 4.) Plaintiff admits


1
    Plaintiff insists CW1 was employed by TI’s parent, (Opp. 11-12), but CW1 worked for TELUS
    Communications Inc., a subsidiary of TI’s parent TELUS Corporation, which operates
    independently of TI. (¶30.) Plaintiff admits that CW1 was only employed before the class
    period. (Opp. 11.) Pre-class period knowledge is particularly outdated here, given the recent
    rapidity of developments in GenAI. See City of Omaha Police & Fire Ret. Sys. v. Evoqua
    Water Techs. Corp., 450 F. Supp. 3d 379, 411 (S.D.N.Y. 2020) ( “no bright-line rule” against
    pre-Class Period allegations, but the information must be relevant).

                                                  2


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that Defendants did not use the word “only,” (Opp. 9-10), but asserts 13 times that TI “only” or

“merely” had pilot AI offerings. Plaintiff cannot change Defendants’ statements by injecting

words they never said. See In re Stemline Therapeutics, Inc. Sec. Litig., 313 F. Supp. 3d 543, 549

(S.D.N.Y. 2018) (“Plaintiffs cannot make up statements and then attribute them to defendants” to

support fraud claim); In re Amarin Corp. PLC Sec. Litig., 2016 WL 1644623, at *19 (D.N.J. Apr.

26, 2016) (rejecting allegations that “completely mischaracterize[d]” defendant’s statement), aff’d,

689 F. App’x 124 (3d Cir. 2017). There was no “admission” that TI had “only” AI pilots.

       Since every Challenged Statement is allegedly false based on defective CW allegations and

purported “admissions,” Defendants’ motion should be granted.

       Falsity is also not pleaded for each category of Challenged Statements for the following

supplemental reasons:

       As a threshold issue, Plaintiff repeatedly misdescribes the Challenged Statements.

Defendants urge the Court to review the actual statements, excerpted in Exhibit 1, rather than

Plaintiff’s snippets,2 and address them category-by-category:

       AI Offerings Statements: The AI Offerings Statements concern TI’s AI offerings in the

Digital/IT business, including initiatives to leverage GenAI. (Br. 10.) Three CWs worked within

this division and conceded AI capabilities existed, and no CW identified any AI capability that TI

falsely claimed to have. Supra 2-3. Plaintiff lumps other Challenged Statements into this category,

calling it “AI Capabilities,” (Opp. 6-12), but those statements concern different business lines,

about which Plaintiff and his CWs offer no facts. Infra 4-5.


2
    (See, e.g., Opp. 10 (claiming TI purported to have its own “market leading generative AI,”
    citing statement describing TI’s customers as “market leading generative AI foundational
    model builders”); Opp. 7 (inserting “[AI]” in the statement “meaningful [AI] capability at
    scale,” when the “capability” being discussed was TI’s content moderator workforce).

                                                 3


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        The Opposition repeatedly equates AI with GenAI, arguing that the AI Offerings

Statements were false because TI did not develop its own “proprietary” foundational GenAI

model. (Opp. 7.) But TI never claimed to have developed its own GenAI model. TI offered AI

long before GenAI emerged, and continues to do so. (Br. 3-5.) 3 Once GenAI emerged, TI

disclosed that its Digital/IT business uses foundational GenAI models (like ChatGPT) as a base

and builds custom applications tailored to customer needs. (Br. 12; e.g., Ex. 6 at 8 (“The

possibilities presented by ChatGPT and similar alternatives are seemingly endless”). The CWs

admit this. (Opp. 7 (TI “build[s] apps around [ChatGPT]”); Opp. 8 (TI “co-develop[s] products

with…customers” on a “case-by-case” basis.).) Thus, TI never claimed to develop its own GenAI

model, but rather, offers unique, customer-centric AI-powered capabilities, which are proprietary

to TI. (Br. 4-6.) Plaintiff’s cited cases (Opp. 8) concern companies that, unlike TI, misstated their

capabilities.

        AI Data Statements: The AI Data Statements concern TI’s data annotation business,

which assists clients in training AI models (often called “large language models” or “LLMs”).

(Br. 5, 13-14.) The Opposition concedes that TI offers AI data annotation services and, indeed,

“enter[ed] the AI market” by establishing this business line. (Opp. 2.) Plaintiff makes no

arguments that any statement about data annotation is false. (Opp. 9-10.) Conceding this, Plaintiff

argues instead that the AI Data Statements are not about data annotation. (Opp. 10.) Not so. For

example, Plaintiff says that TI “falsely claim[ed] Telus was ‘seeing good…demand,’ particularly

for its ‘market-leading generative AI,’” (Opp. 10), but the statement expressly described an

“encouraging year for our AI Data Solutions business” with demand “led by the work we do to


3
    Plaintiff distorts Defendants’ statements to suggest that TI misrepresented that “new” GenAI
    capabilities had been “perfected [] over the last many years.” (Opp. 8.)

                                                 4


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support market-leading generative AI foundational model builders.” (¶119.) Likewise, Plaintiff

challenges the reference to a “near-term gold rush,” but ignores that it referred to “helping the

hyperscalers 4 build…large language models”—i.e., data annotation services. (¶147.) These

statements undoubtedly describe AI Data annotation services, which Plaintiff concedes existed.

       Outlook Statements: Defendants’ motion showed that the Outlook Statements, offering

TI’s positive views on AI, are not actionable because (1) the Complaint does not allege any

Defendant did not subjectively hold these opinions; (2) they are puffery; and (3) they are protected

forward-looking statements. (Br. 15-18.) Plaintiff’s arguments in response fail:

       First, Plaintiff’s semantic argument that statements are not forward-looking if phrased in

present or past tense (Opp. 15), is contrary to settled law. The Outlook Statements “endorse or

state the speaker’s belief in a certain future outlook” and thus “satisfy the PSLRA forward-looking

requirement.” Gray v. Wesco Aircraft Holdings, Inc., 454 F. Supp. 3d 366, 387 (S.D.N.Y. 2020),

aff'd, 847 F. App’x 35 (2d Cir. 2021); (See, e.g., ¶108 (“we’ll continue to be able to distinguish

ourselves from the competition”); ¶111 (“there are meaningful opportunities ahead”); ¶133 (“AI

is going to be the standout for us”); ¶143 (“we anticipate demand starting to recover”).)5

       Second, Plaintiff strains to characterize the Outlook Statements as “incorporat[ing] a

present fact” about TI’s AI capabilities. (Opp. 16.) But “all statements of projections come with

the implied statement that they…are based on recent…performance,” which does not exclude them

from the PSLRA safe harbor. Wesco, 454 F. Supp. 3d at 390. Anyway, TI did have AI capabilities,

so any such implied “fact” is accurate. Supra 1-4.


4
    “Hyperscalers” are large cloud computing companies, such as Google Cloud and Amazon Web
    Services. TI has never purported to be a hyperscaler.
5
    Plaintiff’s cited cases are inapposite because the statements at issue concerned present
    conditions. (Opp. 15-16.)

                                                 5


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       Third, Plaintiff argues that the Outlook Statements are not inactionable opinion6 or puffery

because they are based on “false embedded representations,” (Opp. 18), and “objectively verifiable

facts,” (Opp. 19.) But many Statements provide no verifiable facts at all, and Plaintiff fails to cite

any fact that is actually false. Supra 1-5. Plaintiff certainly cites no facts showing that any

Individual Defendant did not honestly hold the expressed opinions. (Br. 18.)

       Fourth, Plaintiff reframes a subset of the Outlook Statements as “Pricing Statements.”

Plaintiff argues that Defendants “assured investors that Telus could command high prices for its

offerings” only to “belatedly reveal[] Telus had been cutting its prices.” (Opp. 14-15.) Defendants

said no such thing, and neither do the documents Plaintiff cites. (Opp. 14; ¶108.) To the contrary,

Defendants warned that pricing was “absolutely getting more challenging” and made no

assurances about commanding high prices. (Ex. 11 at 10.)7

       Contrary to Plaintiff’s claim that pricing risks were presented as hypothetical (Opp. 14), TI

repeatedly discussed increasing pricing pressure and the need to reduce prices to win business.

(See Ex. 11 at 10 (“[t]he pricing environment has continued to get more and more competitive”

and “it’s becoming more and more of that Sophie’s Choice challenge of just how much of a

tradeoff on margin yield through price reductions are we willing to tolerate”); Ex. 12 at 14

(“pricing sensitivity has indeed amplified” but TI was “not willing to discount our prices so much

so that the margin yield implications are catastrophic”); Ex. 14 at 15 (describing a “pervasive,


6
    That opinions must be preceded by explicit belief language (Opp. 18) has been deemed “not
    necessary.” In Re Philip Morris Int’l Inc. Sec. Litig., 89 F.4th 408, 418 (2d Cir. 2023).
7
    Plaintiff challenges Puritt’s statement that he was “supremely confident” of TI’s visibility into
    its 2023 guidance, which is not about pricing, and there is no allegation of subjective falsity.

                                                  6


         Case 1:25-cv-00889-VM         Document 39        Filed 01/14/26      Page 11 of 18


persistent pressure around more for less” making it difficult to “capture the demand opportunity at

those pressurized price points but still generate our targeted margin yield”).8

         Cost Savings Statements: Plaintiff fails to plead that projections of AI-based internal

cost-savings were false. (Br. 19.) Plaintiff concedes that TI actioned internal cost savings plans,

but says they were not AI-based. (Opp. 13.) This assertion is unsupported by any fact. None of

the CWs claim visibility into senior decisions concerning company-wide cost saving measures,

and two CWs had already departed by the time the Cost Savings Statements were made. In any

event, the CWs claim to have “contributed to automation and AI initiatives” (¶30), which

undermines Plaintiff’s argument.

         The Cost Savings Statements are also forward-looking projections, and Plaintiff does not

plead that any Defendant did not subjectively believe they were achievable. (Opp. 13 (relying on

magnitude of miss, but not arguing subjective falsity); Br. 19-20.) That TI fell short in reducing

costs by the full projected amount does not, in hindsight, make the statements false.

II.      Plaintiff Fails to Plead a Strong Inference of Scienter

         The Opposition weakly argues that Plaintiff has pleaded scienter. Plaintiff barely addresses

the Individual Defendants—even though he is required to separately plead intent of every named

Defendant—and his remaining arguments are meritless.

         No Motive. Plaintiff does not dispute that motive is not pleaded for any Defendant. (Br.

21.) Absent motive, Plaintiff must supply correspondingly greater allegations of conscious

misbehavior or recklessness, which he does not provide.


8
      Unlike In re Facebook, Inc., 986 F. Supp. 2d 487, 515-16 (S.D.N.Y. 2013), Plaintiff pleads no
      facts supporting that the pricing environment deteriorated prior to warnings. And unlike here,
      defendants in In Carmignac Gestion, S.A. v. Perrigo Co. PLC, 2019 WL 3451523, at *11
      (D.N.J. July 31, 2019), falsely promised that the company was “insulated” from pricing issues.

                                                  7


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        No Conscious Misbehavior or Recklessness. Plaintiff concedes he identifies no “specific

reports” showing any Defendant’s knowledge of facts contradicting public statements (Opp. 24

n.21), and admits “the CWs did not directly interact with the Individual Defendants” (Opp. 22).9

These concessions defeat scienter because no pleaded facts support an inference that any

Defendant knowingly made false statements. For Ringman, Plaintiff makes no arguments at all,

(Br. 22-23), thus conceding he must be dismissed. See Colbert v. Rio Tinto PLC, 824 F. App’x

5, 11 (2d Cir. 2020). Plaintiff’s remaining arguments are inadequate:

        Pilots: Plaintiff concedes Puritt did not admit TI had “only” pilot AI offerings, yet still

relies on this erroneous assertion. (Opp. 9.) Bottom line: neither Puritt nor Chande said that TI

offered “only” pilots. Defendants actually said that TI uses pilots for new engagements—an

openly-disclosed fact (Br. 6-7)—and warned that it was seeing “elongated sales cycles” and

“longer decision timeframes” (Br. 7), a warning that is inconsistent with intent to deceive. Plaintiff

calls these disclosures “hypothetical” and “boilerplate.” (Opp. 22.) Nonsense. The use of pilots

and long sale cycles was transparently disclosed.10 “It defies logic to conclude that executives

who are seeking to perpetrate fraudulent information upon the market would make such fulsome

disclosures.” Kuriakose v. Fed. Home Loan Mortg. Corp., 897 F. Supp. 2d 168, 185 (S.D.N.Y.

2012), aff’d, 543 F. App’x 72 (2d Cir. 2013).

        Plaintiff’s cited cases demonstrate the inadequacy of his allegations, because each relied

on internal documents, detailed CW accounts, or other facts establishing a disconnect between

internal information and public statements. See in re Vivendi Universal, S.A. Sec. Litig., 765 F.


9
     In contrast, the CWs in In re Avon Securities Litigation, 2019 WL 6115349 (S.D.N.Y. Nov.
     18, 2019), (Opp. 22), held high-level positions in defendants’ direct reporting lines and
     reviewed documents shared with defendants. Id. at *2, *6.
10
     In re Synchrony Fin. Sec. Litig., 2022 WL 427499, at *10 (D. Conn. Feb. 11, 2022), the
     defendant represented that the disclosed risk had not materialized–the opposite happened here.

                                                  8


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Supp. 2d 512, 547 (S.D.N.Y. 2011) (“stark contrast between…internal documents and [] external

statements”), aff’d, 838 F.3d 223 (2d Cir. 2016); Emps.’ Ret. Sys. v. Blanford, 794 F.3d 297, 308

(2d Cir. 2015) (CWs detailed “efforts to deceive auditors and investors”); Stadium Cap. LLC v.

Co-Diagnostics, Inc., 2024 WL 456745, at *5-6 (S.D.N.Y. Feb. 5, 2024) (defendant admitted they

“saw the…falloff” as the “second quarter progressed”). Such allegations are absent here.

       Pricing Pressures: Plaintiff argues that scienter is pleaded by belated “admissions” that

TI was harmed by price competition. (Opp. 21-23.) This argument is irrelevant to Plaintiff’s claim

that TI lied about its AI capabilities. If anything, pricing adjustments presuppose the existence of

sold products and services. In re DNTW Chartered Accountants Sec. Litig., 172 F. Supp. 3d 675,

689 (S.D.N.Y.) (rejecting “assertion…contradicted by Plaintiffs’ other allegations”), aff’d, 666 F.

App’x 78 (2d Cir. 2016). In any event, TI made robust disclosures warning about immense pricing

pressures and price discounts. (Ex. 12 at 14; Ex. 11 at 10.) These disclosures support an opposite

inference to fraud.

       Cost Savings: Plaintiff contends Defendants “knew” that TI lacked AI capabilities, and

thus could not achieve projected AI-based cost efficiencies. (Opp. 23.) But Plaintiff fails to

identify any internal cost-cutting initiative TI claimed but lacked, or what contradictory

information Defendants knew and when. Hampshire Equity Partners II, L.P. v. Teradyne, Inc.,

2005 WL 736217, at *4 (S.D.N.Y. Mar. 30, 2005) (complaint “not only…fail[s] to describe any

documents, reports, or conversations…[but also] alleges almost no supporting facts at all”), aff’d,

159 F. App’x 317 (2d Cir. 2005). Absent such facts, missed forecasts do not support fraud. City

of Sterling Heights Police & Fire Ret. Sys. v. Vodafone Grp. Pub. Co., 655 F. Supp. 2d 262, 269

(S.D.N.Y. 2009).


                                                 9


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        Remaining Arguments:         Plaintiff resorts to arguments routinely rejected under the

PSLRA. That Defendants spoke about the Company, revenues, and margins is insufficient to

support scienter without particularized facts supporting fraud.11 (Br. 23-24.) Likewise, generic

claims of “visibility” into operations (Opp. 24 & n.21) are not sufficient to plead contemporaneous

knowledge of unidentified contrary facts. Turquoise Hill, 625 F. Supp. 3d 164, 238 (S.D.N.Y.

2022) (rejecting purported “admissions…that [defendants] were ‘plugged in’ and had ‘visibility’”

without particularized facts). Plaintiff also does not refute that the core operations doctrine—if it

exists at all—can serve only as supplemental evidence of scienter, and pleads neither a “core

operation” Defendants misrepresented, nor the requisite additional support. (Br. 24-25.)12

                                            * * * * *

        Plaintiff fails to raise an inference of fraudulent intent that is “cogent and at least as

compelling as any opposing inference.” Teamsters Loc. 445 Freight Div. Pension Fund v. Dynex

Cap. Inc., 531 F.3d 190, 194 (2d Cir. 2008). Plaintiff identifies no motive to lie and no facts

supporting that Defendants intentionally misrepresented their optimism about TI’s outlook and

AI-related capabilities. The far more compelling inference is that, amid difficult macroeconomic


11
     Plaintiff’s own cases show that mere discussion of a topic cannot establish scienter, without
     factual allegations showing access to contradictory information. In re Nielsen Holdings PLC
     Sec. Litig., 510 F. Supp. 3d 217, 227 (S.D.N.Y. 2021) (defendant admitted “we saw these
     [declining spending] trends unfolding” “earlier this year”); In re STMicroelectronics N.V. Sec.
     Litig., 2025 WL 2644241, at *3 (S.D.N.Y. Sept. 15, 2025) (defendant was “called out…in
     senior staff meetings” by CW); Yannes v. SCWorx Corp., 2021 WL 2555437, at *5 (S.D.N.Y.
     June 21, 2021) (defendant “personally ‘spent weeks researching’”); In re Alstom SA Sec. Litig.,
     406 F. Supp. 2d 433, 457, 460 (S.D.N.Y. 2005) (defendants were “direct[ly] involved in the
     day-to-day operations”).
12
     In all three cases Plaintiff cites, the statements concerned critical aspects of the company’s
     business, unlike here, and the court recognized that the doctrine could only supplement
     scienter. (Opp. 25.)

                                                 10


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conditions and competition—which Defendants disclosed—Defendants were optimistic about TI’s

continued development of AI offerings, including (as disclosed) through pilots.

III.      Plaintiff Fails to Plead Loss Causation

          Because neither alleged corrective disclosure revealed the falsity of any Challenged

Statement, the Complaint does not plead loss causation.

          May 9, 2024. Plaintiff admits TI disclosed disappointing 1Q24 financial results on May

9, 2024, but claims that this disclosure corrected TI’s prior false statements by attributing its

revenue misses to AI pilots, revealing that it had no AI offerings. (Opp. 26-27.) Again, TI did not

say this.      Rather, Defendants discussed pilots as indicating “expanding opportunities” and

“momentum” for future revenue—and did not say that TI had no AI offerings. (Ex. 16 at 4-5.)13

The analyst report Plaintiff cites says nothing about the status of TI’s AI offerings or use of pilots—

it correctly attributed TI’s revenue miss to the fact that customer “spending has trended negative

across the IT Services/BPO space through Q1,” and noted “cost-saving initiatives” among other

changes needed to improve margins. (Ex. 19 at 1.)14

          August 2, 2024. TI’s 2Q24 earnings announcement likewise did not “correct” any

Challenged Statement, instead disclosing disappointing results and reduced guidance. (Br. 26.)

Plaintiff seizes on Defendants’ report that it would take longer than anticipated to realize projected

cost savings from TI’s internal cost-cutting initiatives, but ignores cases showing that delays in

achieving results is not corrective of earlier projections. (Br. 25-26.) Nothing in TI’s August 2

disclosure revealed that TI lacked any previously professed AI capability. (Br. 2, 27.) Further,


13
       This is unlike Abramson v. Newlink Genetics Corp., 965 F.3d 165, 179-80 (2d Cir. 2020),
       where the corrective disclosure revealed that the clinical trial failed due to concealed, improper
       study design.
14
       Boston Ret. Sys. v. Alexion Pharms., Inc., 556 F. Supp. 3d 100, 141 (D. Conn. 2021), where
       such analyst commentary did exist, is inapposite.

                                                    11


      Case 1:25-cv-00889-VM          Document 39       Filed 01/14/26    Page 16 of 18


TI’s disclosures about reduced margins and pricing pressures revealed nothing new because TI

had previously disclosed those pressures. (Supra 6-7; Br. 26-27.)

                                       CONCLUSION

       Defendants respectfully seek dismissal of the Complaint with prejudice.


                                               12


      Case 1:25-cv-00889-VM   Document 39    Filed 01/14/26      Page 17 of 18


Dated: January 14, 2026            Respectfully submitted,

New York, New York

                                   PAUL, WEISS, RIFKIND,
                                   WHARTON & GARRISON LLP
                                   /s/ Audra J. Soloway
                                   Audra J. Soloway
                                   Emily M. Miller
                                   1285 Avenue of the Americas
                                   New York, NY 10019-6064
                                   Phone: (212) 373-3000
                                   [email protected]
                                   [email protected]

                                   Counsel for TELUS International (CDA) Inc., Jeffrey
                                   Puritt, Vanessa Kanu, Gopi Chande, and Michael
                                   Ringman


                                     13


       Case 1:25-cv-00889-VM          Document 39        Filed 01/14/26    Page 18 of 18


                              WORD COUNT CERTIFICATION

       I hereby certify that the foregoing document complies with the word count limit set forth

in Local Civil Rule 7.1. I relied on the word count of the word-processing system used to prepare

the document. The total number of words in this document, exclusive of the caption, table of

contents, table of authorities, and signature block, is 3,500 words.


                                                              /s/_Audra J. Soloway____
                                                              Audra J. Soloway


                                                 14