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Chuang, United States District Court, District of Maryland, 6500\n\nCherrywood Lane, Suite 245, Greenbelt, Maryland 20770, pursuant to Section 21D(a)(3) of the\n\nSecurities Exchange Act of 1934, 15 U.S.C. \u00a7 78u-4(a)(3), as amended by the Private Securities\n\nLitigation Reform Act of 1995 (the \u201cPSLRA\u201d), for the entry of an Order: (1) appointing the Cao-\n\nWu Family and Rainwater as Co-Lead Plaintiffs on behalf of a class (the \u201cClass\u201d) consisting of all\n\ninvestors who purchased or otherwise acquired Altimmune, Inc. securities between August 10,\n\n2023 and June 25, 2025, inclusive; and (2) approving proposed Co-Lead Plaintiffs\u2019 selection of\n\nPomerantz LLP as Lead Counsel and Cohen Milstein Sellers & Toll PLLC as Liaison Counsel for\n\nthe Class (the \u201cLead Plaintiff Motion\u201d).\n\n The Cao-Wu Family and Rainwater are aware of Rule II.A. of the Case Management Order\n\nof the Honorable Theodore D. Chuang (the \u201cCase Management Order\u201d) (Dkt. No. 2), which\n\nprovides, inter alia, that \u201c[n]o motions may be filed without first seeking a Pre-Motion Conference\n\nwith the Court[,]\u201d that \u201c[i]f a party intends to file a motion, it must first file a Notice of Intent to\n\nFile a Motion (\u2018Notice\u2019),\u201d which \u201cshall state whether the parties have met and conferred to discuss\n\nwhether the matter at issue can be resolved without a motion[,]\u201d and that, \u201c[u]pon receipt of a\n\nNotice, the Court promptly will schedule a telephonic Pre-Motion Conference with all parties.\u201d\n\nHere, pursuant to the PSLRA, the statutory deadline to file a motion for appointment as Lead\n\nPlaintiff in the above-captioned action is October 6, 2025, on which date any member of the\n\nputative Class may so move. See 15 U.S.C. \u00a7 78u-4(a)(3)(A)(i)(II). The Cao-Wu Family and\n\f Case 8:25-cv-02581-TDC Document 14 Filed 10/06/25 Page 3 of 5\n\n\n\nRainwater will thus not know the identities of all other putative Class members who intend to file\n\ncompeting Lead Plaintiff motions until the deadline has passed, making conferral with all opposing\n\nparties prior to the filing of the Lead Plaintiff Motion impracticable. Under these circumstances,\n\nthe Cao-Wu Family and Rainwater respectfully request that compliance with Rule II.A. of the Case\n\nManagement Order be waived in this instance. Alternatively, the Cao-Wu Family and Rainwater\n\nrespectfully submit that the 60-day PSLRA deadline falls within the circumstances contemplated\n\nin the preamble to the Case Management Order, which states that the Case Management Order\n\n\u201cdoes not, and is not intended to, modify or abridge any substantive rights of any litigant.\u201d\n\nDated: October 6, 2025 Respectfully submitted,\n\n /s/ Daniel S. Sommers\n Daniel S. Sommers (Md. Bar No. 15822)\n S. Douglas Bunch\n COHEN MILSTEIN SELLERS &\n TOLL PLLC\n 1100 New York Avenue, N.W., Suite 800\n Washington, D.C. 20005\n Telephone: (202) 408-4600\n Facsimile: (202) 408-4699\n dsommers@cohenmilstein.com\n dbunch@cohenmilstein.com\n\n Counsel for Co-Lead Plaintiff Movants the Cao-Wu\n Family and Thomas Rainwater and Proposed\n Liaison Counsel for the Class\n\n POMERANTZ LLP\n Jeremy A. Lieberman*\n J. Alexander Hood II*\n 600 Third Avenue, 20th Floor\n New York, New York 10016\n Telephone: (212) 661-1100\n Facsimile: (917) 463-1044\n jalieberman@pomlaw.com\n ahood@pomlaw.com\n\n\n\n\n 2\n\fCase 8:25-cv-02581-TDC Document 14 Filed 10/06/25 Page 4 of 5\n\n\n\n Counsel for Co-Lead Plaintiff Movants the Cao-Wu\n Family and Thomas Rainwater and Proposed Lead\n Counsel for the Class\n\n BRONSTEIN, GEWIRTZ &\n GROSSMAN, LLC\n Peretz Bronstein*\n 60 East 42nd Street, Suite 4600\n New York, New York 10165\n Telephone: (212) 697-6484\n Facsimile: (212) 697-7296\n peretz@bgandg.com\n\n Additional Counsel for Co-Lead Plaintiff Movant\n the Cao-Wu Family\n\n *Pro hac vice applications forthcoming\n\n\n\n\n 3\n\f Case 8:25-cv-02581-TDC Document 14 Filed 10/06/25 Page 5 of 5\n\n\n\n CERTIFICATE OF SERVICE\n\n I hereby certify that a true and correct copy of the foregoing was served by the Court\u2019s\n\nCM/ECF system on counsel of record on this 6th day of October, 2025.\n\nDated: October 6, 2025\n\n /s/ Daniel S. Sommers\n Daniel S. Sommers (Md. Bar No. 15822)\n\n\n\n\n 4\n\f","ocr_status":2,"date_upload":"2026-05-18T06:03:41.465921-07:00","document_number":"14","attachment_number":null,"pacer_doc_id":"093015216137","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528443/","id":479528443,"tags":[],"absolute_url":"/docket/71033169/14/1/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:41.915612-07:00","date_modified":"2026-05-22T03:43:55.116432-07:00","sha1":"3d00a68488d5b896da9e92508c262b10615d9f86","page_count":20,"file_size":254143,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 1 of 20\n\n\n\n UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF MARYLAND\n (Southern Division)\n\n\nDAVE COLLIER, Individually and on Behalf Case No. 8:25-cv-02581-TDC\nof All Others Similarly Situated,\n\n Plaintiff,\n\n v.\n\nALTIMMUNE, INC. et al.,\n\n Defendants.\n\n\n\n MEMORANDUM OF LAW IN SUPPORT OF MOTION OF THE CAO-WU FAMILY\nAND THOMAS RAINWATER FOR APPOINTMENT AS CO-LEAD PLAINTIFFS AND\n APPROVAL OF SELECTION OF COUNSEL\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 2 of 20\n\n\n\n TABLE OF CONTENTS\n\n Page\n\nSUMMARY OF ARGUMENT ...................................................................................................... 1\n\nSTATEMENT OF FACTS ............................................................................................................. 2\n\nARGUMENT .................................................................................................................................. 4\n\n I. THE CAO-WU FAMILY AND RAINWATER SHOULD BE APPOINTED\n CO-LEAD PLAINTIFFS ........................................................................................ 4\n\n A. The Cao-Wu Family and Rainwater Are Willing to Serve as Class\n Representatives and Have Timely Filed This Motion to Be Appointed\n Co-Lead Plaintiffs. ...................................................................................... 5\n\n B. The Cao-Wu Family and Rainwater Have the \u201cLargest Financial Interest\u201d\n in the Action. ............................................................................................... 5\n\n C. The Cao-Wu Family and Rainwater Otherwise Satisfy the Requirements\n of Rule 23. ................................................................................................... 7\n\n D. The Cao-Wu Family and Rainwater Will Fairly and Adequately Represent\n the Interests of the Class and Are Not Subject to Unique Defenses. ........ 10\n\n II. CO-LEAD PLAINTIFFS\u2019 SELECTION OF COUNSEL SHOULD BE\n APPROVED ......................................................................................................... 11\n\nCONCLUSION ............................................................................................................................. 13\n\n\n\n\n i\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 3 of 20\n\n\n\n TABLE OF AUTHORITIES\n\nCases Page(s)\n\nBarnet v. Elan Corp., PLC,\n 236 F.R.D. 158 (S.D.N.Y. 2005) ...............................................................................................9\n\nChamblee v. Terraform Power, Inc.,\n No. PX 16-981, 2016 WL 4039178 (D. Md. July 28, 2016) .................................................7, 8\n\nChina Agritech v. Michael H. Resh,\n 584 U.S. 732 (2018) ...................................................................................................................9\n\nDeLuca v. Instadose Pharma Corp.,\n No. 2:21CV675 (RCY), 2022 WL 3020417 (E.D. Va. July 29, 2022)......................................6\n\nFine, et al. v. Bowl America, Inc., et al.,\n No. 1:21-cv-01967-SAG (D. Md.) ...........................................................................................13\n\nHirtenstein v. Cempra, Inc.,\n Nos. 1:16cv1303 et al., 2017 WL 2874588 (M.D.N.C. July 5, 2017).......................................7\n\nIn re Blue Apron Holdings, Inc. Sec. Litig.,\n No. 17-CV-4846 (WFK) (PK), 2017 WL 6403513 (E.D.N.Y. Dec. 15, 2017).......................10\n\nIn re Cendant Corp. Litig.,\n 264 F.3d 201 (3d Cir. 2001)...................................................................................................6, 9\n\nIn re Comverse Tech., Inc. Sec. Litig.,\n No. 06-CV-1825 (NGG) (RER), 2007 WL 680779 (E.D.N.Y. Mar. 2, 2007) ..........................6\n\nIn re Comverse Technology, Inc. Securities Litigation,\n No. 1:06-cv-01825 (E.D.N.Y.) ................................................................................................12\n\nIn re Emergent BioSolutions Inc. Sec. Litig.,\n No. 8:21-cv-00955-DLB (D. Md.) ...........................................................................................13\n\nIn re Microstrategy Sec. Litig.,\n 110 F. Supp. 2d 427 (E.D. Va. 2000) ......................................................................................11\n\nIn re Molson Coors Brewing Co. Sec. Litig.,\n 233 F.R.D. 147 (D. Del. 2005) ................................................................................................11\n\nIn re Olsten Corp. Sec. Litig.,\n 3 F. Supp. 2d 286 (E.D.N.Y. 1998) ...........................................................................................6\n\nIn re Petrobras Securities Litigation,\n No. 14-cv-09662 (S.D.N.Y.)..............................................................................................11, 12\n\n\n\n ii\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 4 of 20\n\n\n\nIn re Royal Ahold N.V. Sec. & ERISA Litig.,\n 219 F.R.D. 343 (D. Md. 2003)...................................................................................................7\n\nIn re Wells Fargo & Co. Sec. Litig.,\n No. 1:20-cv-04494-JLR-SN (S.D.N.Y.) ..................................................................................12\n\nJohnson v. Pozen, Inc.,\n No. 1:07CV599, 2008 WL 474334 (M.D.N.C. Feb. 15, 2008) .............................................7, 8\n\nKaplan v. S.A.C. Capital Advisors, L.P.,\n 311 F.R.D. 373 (S.D.N.Y. 2015) .............................................................................................11\n\nLax v. First Merchants Acceptance Corp.,\n No. 97 C 2715, 1997 WL 461036 (N.D. Ill. Aug. 6, 1997) ......................................................6\n\nLouisiana Mun. Police Emps.\u2019 Ret. Sys. v. Green Mountain Coffee Roasters, Inc.,\n No. 2:11-CV-289, 2012 WL 12985571 (D. Vt. Apr. 27, 2012) ..............................................10\n\nMaine State Ret. Sys. v. Countrywide Fin. Corp.,\n No. 10-cv-00302-MRPMAN (C.D. Cal.) ................................................................................12\n\nNew Jersey Carpenters Health Fund v. Residential Capital, LLC,\n No. 08-cv-8781 (HB) (S.D.N.Y.) ............................................................................................12\n\nPalm Tran, Inc. - Amalgamated Transit Union Loc. 1577 Pension Plan v.\nEmergent Biosolutions Inc.,\n No. PWG-21-1189, 2021 WL 6072812 (D. Md. Dec. 23, 2021) ......................................6, 8, 9\n\nRubin v. MF Global, Ltd.,\n No. 08-cv-2233 (VM) (S.D.N.Y.)............................................................................................12\n\nSinnathurai v. Novavax, Inc. et al.,\n No. 8:21-cv-02910-TDC (D. Md.) ...........................................................................................13\n\nTchatchou v. India Globalization Cap., Inc.,\n No. 8:18-CV-03396-PWG, 2019 WL 1004591 (D. Md. Feb. 28, 2019) ...................6, 9, 10, 13\n\nStatutes\n\n15 U.S.C. \u00a7 78u-4(a)(3)(A)(i) ..........................................................................................................4\n\n15 U.S.C. \u00a7 78u-4(a)(3)(B) ..........................................................................................................1, 4\n\n15 U.S.C. \u00a7 78u-4(a)(3)(B)(iii)(I)(bb) .........................................................................................5, 6\n\n15 U.S.C. \u00a7 78u-4(a)(3)(B)(iii)(II) .................................................................................................10\n\n15 U.S.C. \u00a7 78u-4(a)(3)(B)(v) ...................................................................................................8, 11\n\n\n\n iii\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 5 of 20\n\n\n\nSecurities Exchange Act of 1934 .............................................................................................1, 5, 7\n\nPrivate Securities Litigation Reform Act of 1995 ................................................................. passim\n\nRules\n\nFederal Rules of Civil Rule 23............................................................................................... passim\n\n\n\n\n iv\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 6 of 20\n\n\n\n Movants Yiming Cao (\u201cCao\u201d), Yaping Wu (\u201cWu\u201d and, together with Cao, the \u201cCao-Wu\n\nFamily\u201d), and Thomas Rainwater (\u201cRainwater\u201d) respectfully submit this memorandum of law in\n\nsupport of their motion, pursuant to Section 21D(a)(3) of the Securities Exchange Act of 1934 (the\n\n\u201cExchange Act\u201d), 15 U.S.C. \u00a7 78u-4(a)(3), as amended by the Private Securities Litigation Reform\n\nAct of 1995 (the \u201cPSLRA\u201d), for the entry of an Order: (1) appointing the Cao-Wu Family and\n\nRainwater as Co-Lead Plaintiffs on behalf of a class (the \u201cClass\u201d) consisting of all investors who\n\npurchased or otherwise acquired Altimmune, Inc. (\u201cAltimmune\u201d or the \u201cCompany\u201d) securities\n\nbetween August 10, 2023 and June 25, 2025, inclusive (the \u201cClass Period\u201d); and (2) approving\n\nproposed Co-Lead Plaintiffs\u2019 selection of Pomerantz LLP (\u201cPomerantz\u201d) as Lead Counsel and\n\nCohen Milstein Sellers & Toll PLLC (\u201cCohen Milstein\u201d) as Liaison Counsel for the Class.\n\n SUMMARY OF ARGUMENT\n\n The complaint (\u201cComplaint\u201d) (Dkt. No. 1) in the above-captioned action (the \u201cAction\u201d)\n\nalleges that the above-captioned defendants (\u201cDefendants\u201d) defrauded investors in violation of the\n\nExchange Act. Altimmune investors, including the Cao-Wu Family and Rainwater, incurred\n\nsignificant losses following the disclosures of the alleged fraud, which caused Altimmune\u2019s share\n\nprice to fall sharply, damaging the Cao-Wu Family, Rainwater, and other Altimmune investors.\n\n Pursuant to the PSLRA, the Court is to appoint as Lead Plaintiff the movant or group of\n\nmovants that possesses the largest financial interest in the outcome of the Action and that satisfies\n\nthe requirements of Federal Rule of Civil Procedure 23 (\u201cRule 23\u201d). 15 U.S.C. \u00a7 78u-\n\n4(a)(3)(B)(iii)(I). In connection with their transactions in Altimmune securities during the Class\n\nPeriod, the Cao-Wu Family and Rainwater collectively incurred losses of approximately $80,602.\n\nSee Declaration of Jeremy A. Lieberman in Support of Motion (\u201cLieberman Decl.\u201d), Exhibit\n\n(\u201cEx.\u201d) 1, J.R.000002-05. Accordingly, the Cao-Wu Family and Rainwater believe that they have\n\nthe largest financial interest in the relief sought in this Action. Beyond their considerable financial\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 7 of 20\n\n\n\ninterest, the Cao-Wu Family and Rainwater also meet the applicable requirements of Rule 23\n\nbecause their claims are typical of those of absent Class members and they will fairly and\n\nadequately represent the interests of the Class.\n\n To fulfill their obligations as Co-Lead Plaintiffs and vigorously prosecute the Action on\n\nbehalf of the Class, the Cao-Wu Family and Rainwater have selected Pomerantz as Lead Counsel\n\nand Cohen Milstein as Liaison Counsel for the Class. These firms and their attorneys are highly\n\nexperienced in the areas of securities litigation and class actions, and have successfully prosecuted\n\nnumerous securities litigations and securities fraud class actions on behalf of investors, as detailed\n\nfurther in Section II., infra.\n\n Accordingly, the Cao-Wu Family and Rainwater respectfully request that the Court enter\n\nan order appointing them as Co-Lead Plaintiffs for the Class and approving their selection of\n\nPomerantz as Lead Counsel and Cohen Milstein as Liaison Counsel for the Class.\n\n STATEMENT OF FACTS\n\n As alleged in the Complaint in the Action, the alleged misrepresentations in this case relate\n\nto Altimmune\u2019s failure to achieve statistical significance in its analysis of the fibrosis reduction\n\nprimary endpoint in its IMPACT Phase 2b MASH trial of the drug Pemvidutide. In pertinent part,\n\nDefendants provided the public with overwhelmingly positive statements leading up to the\n\nannouncement of topline results that failed to account for the fibrosis reduction observed in the\n\nplacebo group.\n\n Defendants provided these overwhelmingly positive statements to investors while, at the\n\nsame time, misrepresenting and/or concealing material adverse facts concerning the true state of\n\nthe results observed in Altimmune\u2019s IMPACT Phase 2b MASH trial. Altimmune\u2019s executives\n\nrepeatedly touted their positive expectations and even went as far as to title the press release\n\nannouncing the IMPACT Phase 2b MASH trial topline results \u201cAnnounces Positive Topline\n\n\n 2\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 8 of 20\n\n\n\nResults from the IMPACT Phase 2b MASH trial of Pemvidutide in the Treatment of MASH\n\n[metabolic associated steatohepatitis],\u201d completely disregarding that one of two primary endpoints\n\nwas not found to be statistically significant. In fact, Defendants spent minimal time discussing the\n\naforementioned failure during the special call hosted by Altimmune pertaining to the topline\n\nresults, instead stating that the Company hoped for better results in the Phase 3 trial.\n\n On June 26, 2025, Altimmune published a press release announcing topline results from\n\nthe IMPACT Phase 2b MASH trial of Pemvidutide in the Treatment of MASH. While Defendants\n\nhad continuously provided inflated expectations ahead of these results, the analysis showed a clear\n\nfailure by the Company to achieve statistical significance in its analysis of the fibrosis reduction\n\nprimary endpoint in its IMPACT Phase 2b MASH trial. In particular, while a positive trend in\n\nfibrosis improvement was observed, statistical significance was not met due to a higher-than-\n\nexpected placebo response. When questioned about this concerning miss, Defendants answered\n\nindifferently, attributing this result to the Phase 2 nature of the trial and stated that Altimmune was\n\nhoping for better results following the Phase 3 trial.\n\n Investors and analysts reacted immediately to Altimmune\u2019s revelation. The price of\n\nAltimmune\u2019s common stock declined dramatically from a closing market price of $7.71 per share\n\non June 25, 2025, to $3.61 per share on June 26, 2025, a decline of 53.2% in the span of just a\n\nsingle day. Investors who purchased Altimmune stock prior to this disclosure did so based on\n\nmaterially misleading information and suffered damages as a result.\n\n\n\n\n 3\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 9 of 20\n\n\n\n ARGUMENT\n\n I. THE CAO-WU FAMILY AND RAINWATER SHOULD BE APPOINTED CO-\n LEAD PLAINTIFFS\n\n The Cao-Wu Family and Rainwater should be appointed Co-Lead Plaintiffs because they\n\nhave timely filed a motion for appointment as Co-Lead Plaintiffs, have the largest financial interest\n\nin this Action to their knowledge, and otherwise strongly satisfy the requirements of Rule 23.\n\n The PSLRA requires the plaintiff who files an action governed by its provisions to publish\n\na notice (the \u201cNotice\u201d) to the class within 20 days of filing the action, informing putative class\n\nmembers of: (1) the pendency of the action; and (2) their right to file a motion for appointment as\n\nlead plaintiff within 60 days after publication of the Notice. See 15 U.S.C. \u00a7 78u-4(a)(3)(A)(i).\n\nAdditionally, the PSLRA directs courts to consider any motion to serve as lead plaintiff filed by\n\nclass members in response to the Notice and to do so by the later of (1) 90 days after the date of\n\npublication, or (2) as soon as practicable after the Court decides any pending motion to consolidate.\n\nSee id. \u00a7 78u-4(a)(3)(B).\n\n Pursuant to the PSLRA, the Court \u201cshall appoint\u201d the \u201cmost adequate plaintiff\u201d to serve as\n\nlead plaintiff. Id. \u00a7 78u-4(a)(3)(B)(i). The PSLRA provides a \u201c[r]ebuttable presumption\u201d that the\n\n\u201cmost adequate plaintiff\u201d is the person or group that:\n\n (aa) has either filed the complaint or made a motion in response to a notice . . .;\n\n (bb) in the determination of the court, has the largest financial interest in the relief\n sought by the class; and\n\n (cc) otherwise satisfies the requirements of Rule 23 of the Federal Rules of Civil\n Procedure.\n\nId. \u00a7 78u-4(a)(3)(B)(iii)(I).\n\n\n\n\n 4\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 10 of 20\n\n\n\n As set forth below, the Cao-Wu Family and Rainwater satisfy all three of these criteria and\n\nthus are entitled to the presumption that they are the most adequate plaintiffs of the Class and,\n\ntherefore, should be appointed Co-Lead Plaintiffs for the Class.\n\n A. The Cao-Wu Family and Rainwater Are Willing to Serve as Class\n Representatives and Have Timely Filed This Motion to Be Appointed Co-\n Lead Plaintiffs.\n\n On August 5, 2025, counsel for plaintiff in the Action caused the statutorily required Notice\n\nto be published via Globe Newswire pursuant to Section 21D(a)(3)(A)(i) of the PSLRA,\n\nannouncing that a securities class action had been filed against Altimmune and other defendants,\n\nand advising investors in Altimmune securities that they had until October 6, 2025\u2014i.e., 60 days\n\nfrom the date of the Notice\u2019s publication\u2014to file a motion to be appointed as lead plaintiff. See\n\nLieberman Decl., Ex. 2, J.R.000007-08.\n\n The Cao-Wu Family and Rainwater have filed the instant motion pursuant to the Notice,\n\nand they have attached sworn Certifications attesting that they are willing to serve as\n\nrepresentatives for the Class and to provide testimony at deposition and trial, if necessary. See id.,\n\nEx. 3, J.R.000010-11, 000013-14, 000016-17. Accordingly, the Cao-Wu Family and Rainwater\n\nsatisfy the first requirement to serve as Co-Lead Plaintiffs of the Class.\n\n B. The Cao-Wu Family and Rainwater Have the \u201cLargest Financial Interest\u201d in\n the Action.\n\n The PSLRA requires a court to adopt a rebuttable presumption that \u201cthe most adequate\n\nplaintiff . . . is the person or group of persons that . . . has the largest financial interest in the relief\n\nsought by the class[.]\u201d 15 U.S.C. \u00a7 78u-4(a)(3)(B)(iii)(I)(bb). To the best of their knowledge, the\n\nCao-Wu Family and Rainwater have the largest financial interest of any Altimmune investor or\n\ninvestor group seeking to serve as Lead Plaintiff. For claims arising under Section 10(b) of the\n\nExchange Act, courts frequently assess financial interest based upon the four factors articulated in\n\n\n\n 5\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 11 of 20\n\n\n\nthe seminal case Lax v. First Merchants Acceptance Corp.: (1) the number of shares purchased\n\nduring the class period; (2) the number of net shares purchased during the class period; (3) the total\n\nnet funds expended during the class period; and (4) the approximate losses suffered. No. 97 C\n\n2715, 1997 WL 461036, at *5 (N.D. Ill. Aug. 6, 1997). These so-called Lax factors have been\n\nadopted and applied by courts nationwide, including in the Fourth Circuit. See Tchatchou v. India\n\nGlobalization Cap., Inc., No. 8:18-CV-03396-PWG, 2019 WL 1004591, at *4 (D. Md. Feb. 28,\n\n2019); In re Cendant Corp. Litig., 264 F.3d 201, 262 (3d Cir. 2001); In re Olsten Corp. Sec. Litig.,\n\n3 F. Supp. 2d 286, 295 (E.D.N.Y. 1998); accord In re Comverse Tech., Inc. Sec. Litig., No. 06-\n\nCV-1825 (NGG) (RER), 2007 WL 680779, at *6-8 (E.D.N.Y. Mar. 2, 2007). Of the Lax factors,\n\ncourts in the Fourth Circuit generally emphasize approximate loss in assessing a lead plaintiff\n\nmovant\u2019s financial interest within the meaning of the PSLRA. See Palm Tran, Inc. - Amalgamated\n\nTransit Union Loc. 1577 Pension Plan v. Emergent Biosolutions Inc., No. PWG-21-1189, 2021\n\nWL 6072812, at *4-5 (D. Md. Dec. 23, 2021) (recognizing loss \u201cis widely considered the most\n\nimportant\u201d financial interest factor and assessing financial interest on that basis); DeLuca v.\n\nInstadose Pharma Corp., No. 2:21CV675 (RCY), 2022 WL 3020417, at *3 (E.D. Va. July 29,\n\n2022) (same).\n\n In connection with their transactions in Altimmune securities during the Class Period, the\n\nCao-Wu Family and Rainwater collectively incurred losses of approximately $80,602. See\n\nLieberman Decl., Ex. 1, J.R.000002-05. To the extent that the Cao-Wu Family and Rainwater\n\npossess the largest financial interest in the outcome of this litigation, they are the presumptive\n\n\u201cmost adequate\u201d plaintiffs. 15 U.S.C. \u00a7 78u-4(a)(3)(B)(iii)(I)(bb).\n\n\n\n\n 6\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 12 of 20\n\n\n\n C. The Cao-Wu Family and Rainwater Otherwise Satisfy the Requirements of\n Rule 23.\n\n Section 21D(a)(3)(B)(iii)(I)(cc) of the PSLRA further provides that, in addition to\n\npossessing the largest financial interest in the outcome of the litigation, lead plaintiffs must\n\n\u201cotherwise satisf[y] the requirements of Rule 23 of the Federal Rules of Civil Procedure[.]\u201d In\n\ndetermining whether lead plaintiff movants satisfy Rule 23\u2019s requirements, the Court need not\n\nraise its inquiry to the level required in ruling on a motion for class certification. Instead, at this\n\nstage of the litigation, only a prima facie showing of typicality and adequacy is required. See\n\nChamblee v. Terraform Power, Inc., No. PX 16-981, 2016 WL 4039178, at *2 (D. Md. July 28,\n\n2016); Hirtenstein v. Cempra, Inc., Nos. 1:16cv1303 et al., 2017 WL 2874588, at *4 (M.D.N.C.\n\nJuly 5, 2017).\n\n \u201cThe requirement of typicality is satisfied if the [lead plaintiff] movant\u2019s claim arises from\n\nthe same course of events as those of the other potential class members and relies on similar legal\n\ntheories to prove the defendants\u2019 liability.\u201d In re Royal Ahold N.V. Sec. & ERISA Litig., 219 F.R.D.\n\n343, 350 (D. Md. 2003); see also Johnson v. Pozen, Inc., No. 1:07CV599, 2008 WL 474334, at *2\n\n(M.D.N.C. Feb. 15, 2008). The Cao-Wu Family\u2019s and Rainwater\u2019s claims are typical of those of\n\nthe Class. The Cao-Wu Family and Rainwater allege, like other Class members, that Defendants\n\nviolated the Exchange Act by making what they knew or should have known were false or\n\nmisleading statements of material facts concerning Altimmune, or by omitting to state material\n\nfacts necessary to make the statements they did make not misleading. The Cao-Wu Family and\n\nRainwater, like other Class members, purchased or otherwise acquired Altimmune securities\n\nduring the Class Period at prices alleged to have been artificially inflated by Defendants\u2019\n\nmisrepresentations or omissions, and were damaged upon the disclosure of those\n\nmisrepresentations and/or omissions that drove Altimmune\u2019s share price downward. These shared\n\n\n\n 7\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 13 of 20\n\n\n\nclaims, which are based on the same legal theory and arise from the same events and course of\n\nconduct as the Class\u2019s claims, satisfy the typicality requirement of Rule 23(a)(3).\n\n \u201cAdequate representation requires a finding that the purported class representative and its\n\nattorney are capable of pursuing the litigation and that neither has a conflict of interest with other\n\nclass members.\u201d Johnson, 2008 WL 474334, at *2; see also Chamblee, 2016 WL 4039178, at *2\n\n(appointing lead plaintiffs that \u201cdemonstrated that they will \u2018fairly and adequately protect the\n\ninterests of the class,\u2019 and \u2018ensure vigorous advocacy\u2019\u201d (quoting Riordan v. Smith Barney, 113\n\nF.R.D. 60, 64 (N.D. Ill. 1986))). The Cao-Wu Family and Rainwater are adequate representatives\n\nfor the Class. As set forth in greater detail below, in Pomerantz and Cohen Milstein, the Cao-Wu\n\nFamily and Rainwater have retained counsel highly experienced in vigorously and efficiently\n\nprosecuting securities class actions such as this Action, and submit their choice of Pomerantz and\n\nCohen Milstein to the Court for approval as Lead Counsel and Liaison Counsel, respectively, for\n\nthe Class pursuant to 15 U.S.C. \u00a7 78u-4(a)(3)(B)(v). In addition to Pomerantz and Cohen Milstein,\n\nthe Cao-Wu Family is also represented by the Bronstein, Gewirtz & Grossman, LLC law firm in\n\nthis Action, which is not seeking appointment or a role as lead or liaison counsel. There is no\n\nevidence of antagonism or conflict between the Cao-Wu Family\u2019s and Rainwater\u2019s interests and\n\nthose of the Class. Moreover, the Cao-Wu Family and Rainwater have submitted sworn\n\nCertifications declaring their commitment to protect the interests of the Class (see Lieberman\n\nDecl., Ex. 3, J.R.000010-11, 000013-14, 000016-17), and their significant financial interest\n\ndemonstrates that they have a sufficient interest in the outcome of this litigation to ensure vigorous\n\nadvocacy on behalf of the Class.\n\n Further, the Cao-Wu Family and Rainwater constitute an appropriate movant group of the\n\ntype routinely appointed to serve as Co-Lead Plaintiffs. See, e.g., Palm Tran, 2021 WL 6072812,\n\n\n\n\n 8\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 14 of 20\n\n\n\nat *5 (appointing movant group, finding \u201c[n]ot having a pre-litigation relationship does not\n\ndisqualify a group, and the parties here represent that they chose to work together based on their\n\nmutual shared interests in maximizing the Class\u2019s recovery\u201d (internal quotation marks omitted));\n\nTchatchou, 2019 WL 1004591, at *7-9 (appointing group of seven as lead plaintiff under the\n\nPSLRA); Barnet v. Elan Corp., PLC, 236 F.R.D. 158, 162-63 (S.D.N.Y. 2005) (holding \u201cthere can\n\nbe no doubt\u201d that the PSLRA permits appointment of groups and appointing group consisting of\n\nsix members with the largest financial interest as lead plaintiffs); see also Cendant, 264 F.3d at\n\n266 (\u201cThe PSLRA explicitly permits a \u2018group of persons\u2019 to serve as lead plaintiff.\u201d (citation\n\nomitted)). Moreover, the Supreme Court recently affirmed the propriety of permitting investor\n\ngroups to serve as Co-Lead Plaintiffs in China Agritech v. Michael H. Resh, 584 U.S. 732 (2018),\n\nnoting that \u201c[d]istrict courts often permit aggregation of plaintiffs into plaintiff groups\u201d in PSLRA\n\nactions. Id. at 742 n.3.\n\n The Cao-Wu Family and Rainwater likewise have demonstrated their adequacy because\n\nthey are a small and cohesive group of three investors\u2014two of whom, Cao and Wu, are a married\n\ncouple\u2014who have submitted a Joint Declaration attesting to, inter alia, their backgrounds, their\n\ninvesting experience, their understanding of the responsibilities of lead plaintiffs appointed\n\npursuant to the PSLRA, their decision to seek appointment jointly as Co-Lead Plaintiffs, and the\n\nsteps that each of them is prepared to take to cooperatively prosecute this litigation on behalf of\n\nthe Class. See Lieberman Decl., Ex. 4, J.R.000021-27. Courts, including in the Fourth Circuit,\n\nroutinely appoint investor groups as Co-Lead Plaintiffs pursuant to the PSLRA under such\n\ncircumstances. See, e.g., Palm Tran, 2021 WL 6072812, at *5-6 (appointing investor group where\n\nits members \u201csubmitted a joint declaration attesting to their discussions with one another and with\n\ncounsel regarding their joint motion, their understanding of their responsibilities, and their\n\n\n\n\n 9\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 15 of 20\n\n\n\nreadiness to take on those responsibilities\u201d); Tchatchou, 2019 WL 1004591, at *8-9 (appointing\n\ninvestor group that submitted a declaration that \u201csignals to [the court] that [the group\u2019s] members\n\nare prepared to play an active role in this litigation and to monitor the actions of their selected\n\ncounsel\u201d); In re Blue Apron Holdings, Inc. Sec. Litig., No. 17-CV-4846 (WFK) (PK), 2017 WL\n\n6403513, at *4-5 (E.D.N.Y. Dec. 15, 2017) (appointing group of four investors that submitted a\n\ndeclaration attesting \u201cit is prepared to work cooperatively to serve the best interests of the class\u201d);\n\nLouisiana Mun. Police Emps.\u2019 Ret. Sys. v. Green Mountain Coffee Roasters, Inc., No. 2:11-CV-\n\n289, 2012 WL 12985571, at *3 (D. Vt. Apr. 27, 2012) (finding joint declaration \u201csufficient to\n\nassure the Court that the [lead] plaintiffs will effectively manage the litigation\u201d).\n\n D. The Cao-Wu Family and Rainwater Will Fairly and Adequately Represent\n the Interests of the Class and Are Not Subject to Unique Defenses.\n\n The presumption favoring the Cao-Wu Family\u2019s and Rainwater\u2019s appointment as Co-Lead\n\nPlaintiffs may be rebutted only upon proof \u201cby a member of the purported plaintiff class\u201d that the\n\npresumptively most adequate plaintiff:\n\n (aa) will not fairly and adequately protect the interests of the class; or\n\n (bb) is subject to unique defenses that render such plaintiff incapable of\n adequately representing the class.\n\n15 U.S.C. \u00a7 78u-4(a)(3)(B)(iii)(II).\n\n The Cao-Wu Family\u2019s and Rainwater\u2019s ability and desire to fairly and adequately represent\n\nthe Class has been discussed above. The Cao-Wu Family and Rainwater are not aware of any\n\nunique defenses Defendants could raise that would render them inadequate to represent the Class.\n\nAccordingly, the Cao-Wu Family and Rainwater should be appointed Co-Lead Plaintiffs for the\n\nClass.\n\n\n\n\n 10\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 16 of 20\n\n\n\nII. CO-LEAD PLAINTIFFS\u2019 SELECTION OF COUNSEL SHOULD BE APPROVED\n\n The PSLRA vests authority in lead plaintiffs to select and retain counsel for the class,\n\nsubject to the approval of the Court. See id. \u00a7 78u-4(a)(3)(B)(v). The Court should only interfere\n\nwith a lead plaintiff\u2019s choice if necessary to \u201cprotect the interests of the class[.]\u201d Id. \u00a7 78u-\n\n4(a)(3)(B)(iii)(II)(aa); see In re Microstrategy Sec. Litig., 110 F. Supp. 2d 427, 438 (E.D. Va.\n\n2000) (\u201c[A] district court should approve plaintiff\u2019s choice of lead counsel based solely on that\n\ncounsel\u2019s competence, experience, and resources[.]\u201d); Kaplan v. S.A.C. Capital Advisors, L.P.,\n\n311 F.R.D. 373, 383 (S.D.N.Y. 2015) (\u201cThe PSLRA \u2018evidences a strong presumption in favor of\n\napproving a properly-selected lead plaintiff\u2019s decisions as to counsel selection and counsel\n\nretention.\u2019\u201d (quoting Varghese v. China Shenghuo Pharm. Holdings, Inc., 589 F. Supp. 2d 388,\n\n398 (S.D.N.Y. 2008))); In re Molson Coors Brewing Co. Sec. Litig., 233 F.R.D. 147, 150 (D. Del.\n\n2005) (\u201cOnce the lead plaintiff is chosen, that party is primarily responsible for selecting lead\n\ncounsel.\u201d).\n\n Here, the Cao-Wu Family and Rainwater have selected Pomerantz as Lead Counsel and\n\nCohen Milstein as Liaison Counsel for the Class. Pomerantz is highly experienced in the areas of\n\nsecurities litigation and class actions, and has successfully prosecuted numerous securities\n\nlitigations and securities fraud class actions on behalf of investors, as detailed in its firm resume\n\nsubmitted herewith. See Lieberman Decl., Ex. 5, J.R.000029-36. In overview, Pomerantz is a\n\npremier firm in the area of securities litigation based in New York, with offices in Chicago, Los\n\nAngeles, Paris, France, London, the U.K., and Tel Aviv, Israel. See id. For more than 85 years,\n\nPomerantz has represented defrauded investors. See id., J.R.000029. As Lead Counsel in In re\n\nPetrobras Securities Litigation, No. 14-cv-09662 (S.D.N.Y.), Pomerantz secured a recovery of $3\n\nbillion on behalf of investors in the securities of Petrobras, the largest settlement ever in a class\n\naction involving a foreign issuer and the fifth-largest class action settlement ever achieved in the\n\n\n 11\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 17 of 20\n\n\n\nUnited States. See id., J.R.000030. Petrobras is part of a long line of record-setting recoveries led\n\nby Pomerantz, including the $225 million settlement in In re Comverse Technology, Inc. Securities\n\nLitigation, No. 1:06-cv-01825 (E.D.N.Y.), in June 2010. See id., J.R.000030-33. More recently,\n\nas Lead Counsel on behalf of a class of Fiat Chrysler Automobiles N.V. investors, Pomerantz\n\nreached a $110 million settlement on behalf of the class. See id., J.R.000030.\n\n Likewise, Cohen Milstein is well-qualified to serve as Liaison Counsel for the Class.\n\nCohen Milstein has worldwide expertise as counsel for U.S. and non-U.S. institutional investors\n\nwho have been the victims of securities fraud. By applying innovative legal theories and litigation\n\nstrategies, it has recovered billions of dollars for its clients in some of the largest and most complex\n\nsecurities class actions. Significant securities settlements obtained by Cohen Milstein, acting as\n\nlead or co-lead counsel, include a $1 billion recovery in a securities class action against Wells\n\nFargo & Co., the seventeenth-largest securities class action recovery in U.S. history (In re Wells\n\nFargo & Co. Sec. Litig., No. 1:20-cv-04494-JLR-SN (S.D.N.Y.)); a $500 million settlement in the\n\nCountrywide mortgage-backed securities (\u201cMBS\u201d) class action (Maine State Ret. Sys. v.\n\nCountrywide Fin. Corp., No. 10-cv-00302-MRPMAN (C.D. Cal.)); a $275 million settlement in\n\nan MBS class action against the Royal Bank of Scotland (New Jersey Carpenters Health Fund v.\n\nThe Royal Bank of Scotland Group, plc, No. 08-cv-05310-DAB-HBP (S.D.N.Y.)); $335 million\n\nin settlements in a class action against Residential Accredit Loans, Inc. and various investment\n\nbanks (New Jersey Carpenters Health Fund v. Residential Capital, LLC, No. 08-cv-8781 (HB)\n\n(S.D.N.Y.)); and a $90 million settlement in a class action against MF Global (Rubin v. MF Global,\n\nLtd., No. 08-cv-2233 (VM) (S.D.N.Y.)), among others. Cohen Milstein\u2019s attorneys have\n\nexperience in achieving substantial recoveries in class actions, and they have extensive familiarity\n\nwith the Local Rules and practice norms of this District, having served as both lead and liaison\n\n\n\n\n 12\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 18 of 20\n\n\n\ncounsel in cases in this District. See, e.g., Sinnathurai v. Novavax, Inc. et al., No. 8:21-cv-02910-\n\nTDC (D. Md.) (liaison counsel with Pomerantz and another firm as co-lead counsel); Tchatchou\n\nv. India Globalization Capital, Inc. et al., No. 8:18-cv-03396-PWG (D. Md.) (same); Fine, et al.\n\nv. Bowl America, Inc., et al., No. 1:21-cv-01967-SAG (D. Md.) (co-lead counsel); In re Emergent\n\nBioSolutions Inc. Sec. Litig., No. 8:21-cv-00955-DLB (D. Md.) (liaison counsel with Pomerantz\n\nas lead counsel).\n\n As a result of their extensive experience in litigation involving issues similar to those raised\n\nin the instant Action, the Cao-Wu Family\u2019s and Rainwater\u2019s counsel, Pomerantz and Cohen\n\nMilstein, have the skill, knowledge, expertise, and experience that will enable these firms to\n\nprosecute this Action effectively and expeditiously. Thus, the Court may be assured that by\n\napproving the Cao-Wu Family\u2019s and Rainwater\u2019s selection of Pomerantz as Lead Counsel and\n\nCohen Milstein as Liaison Counsel, the members of the Class will receive the best legal\n\nrepresentation available.\n\n CONCLUSION\n\n For the foregoing reasons, the Cao-Wu Family and Rainwater respectfully request that the\n\nCourt issue an Order: (1) appointing the Cao-Wu Family and Rainwater as Co-Lead Plaintiffs for\n\nthe Class; and (2) approving their selection of Pomerantz as Lead Counsel and Cohen Milstein as\n\nLiaison Counsel for the Class.\n\nDated: October 6, 2025 Respectfully submitted,\n\n /s/ Daniel S. Sommers\n Daniel S. Sommers (Md. Bar No. 15822)\n S. Douglas Bunch\n COHEN MILSTEIN SELLERS &\n TOLL PLLC\n 1100 New York Avenue, N.W., Suite 800\n Washington, D.C. 20005\n Telephone: (202) 408-4600\n Facsimile: (202) 408-4699\n\n\n 13\n\fCase 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 19 of 20\n\n\n\n dsommers@cohenmilstein.com\n dbunch@cohenmilstein.com\n\n Counsel for Co-Lead Plaintiff Movants the Cao-Wu\n Family and Thomas Rainwater and Proposed\n Liaison Counsel for the Class\n\n POMERANTZ LLP\n Jeremy A. Lieberman*\n J. Alexander Hood II*\n 600 Third Avenue, 20th Floor\n New York, New York 10016\n Telephone: (212) 661-1100\n Facsimile: (917) 463-1044\n jalieberman@pomlaw.com\n ahood@pomlaw.com\n\n Counsel for Co-Lead Plaintiff Movants the Cao-Wu\n Family and Thomas Rainwater and Proposed Lead\n Counsel for the Class\n\n BRONSTEIN, GEWIRTZ &\n GROSSMAN, LLC\n Peretz Bronstein*\n 60 East 42nd Street, Suite 4600\n New York, New York 10165\n Telephone: (212) 697-6484\n Facsimile: (212) 697-7296\n peretz@bgandg.com\n\n Additional Counsel for Co-Lead Plaintiff Movant\n the Cao-Wu Family\n\n *Pro hac vice applications forthcoming\n\n\n\n\n 14\n\f Case 8:25-cv-02581-TDC Document 14-1 Filed 10/06/25 Page 20 of 20\n\n\n\n CERTIFICATE OF SERVICE\n\n I hereby certify that a true and correct copy of the foregoing was served by the Court\u2019s\n\nCM/ECF system on counsel of record on this 6th day of October, 2025.\n\nDated: October 6, 2025\n\n /s/ Daniel S. Sommers\n Daniel S. Sommers (Md. Bar No. 15822)\n\n\n\n\n 15\n\f","ocr_status":2,"date_upload":"2026-05-18T06:03:47.267300-07:00","document_number":"14","attachment_number":1,"pacer_doc_id":"093015216138","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Memorandum in Support","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528444/","id":479528444,"tags":[],"absolute_url":"/docket/71033169/14/2/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:41.931808-07:00","date_modified":"2026-05-22T03:50:06.268296-07:00","sha1":"3a2d28ba02f3c9e4dec5b7320f9857d7c99d6b4a","page_count":3,"file_size":137351,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 14-2 Filed 10/06/25 Page 1 of 3\n\n\n\n UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF MARYLAND\n (Southern Division)\n\n\nDAVE COLLIER, Individually and on Behalf Case No. 8:25-cv-02581-TDC\nof All Others Similarly Situated,\n\n Plaintiff,\n\n v.\n\nALTIMMUNE, INC. et al.,\n\n Defendants.\n\n\n\n DECLARATION OF JEREMY A. LIEBERMAN IN SUPPORT OF MOTION OF THE\nCAO-WU FAMILY AND THOMAS RAINWATER FOR APPOINTMENT AS CO-LEAD\n PLAINTIFFS AND APPROVAL OF SELECTION OF COUNSEL\n\f Case 8:25-cv-02581-TDC Document 14-2 Filed 10/06/25 Page 2 of 3\n\n\n\nI, Jeremy A. Lieberman, hereby declare as follows:\n\n 1. I am an attorney with the law firm of Pomerantz LLP (\u201cPomerantz\u201d), counsel on\n\nbehalf of Yiming Cao (\u201cCao\u201d), Yaping Wu (\u201cWu\u201d and, together with Cao, the \u201cCao-Wu Family\u201d),\n\nand Thomas Rainwater (\u201cRainwater\u201d), and have personal knowledge of the facts set forth herein.\n\nI make this Declaration in support of the Cao-Wu Family\u2019s and Rainwater\u2019s motion for\n\nappointment as Co-Lead Plaintiffs for the Class in the above-captioned action (the \u201cAction\u201d) and\n\napproval of their selection of Pomerantz as Lead Counsel and Cohen Milstein Sellers & Toll PLLC\n\nas Liaison Counsel for the Class in the Action.\n\n 2. Attached hereto as the exhibits indicated are true and correct copies of the\n\nfollowing:\n\n Exhibit 1: Chart setting forth the Cao-Wu Family\u2019s and Rainwater\u2019s financial\n interest in this litigation;\n\n Exhibit 2: Press release published via Globe Newswire on August 5, 2025,\n announcing the pendency of the Action;\n\n Exhibit 3: Shareholder Certifications executed by the members of the Cao-Wu\n Family and Rainwater;\n\n Exhibit 4: Joint Declaration executed by the members of the Cao-Wu Family\n and Rainwater; and\n\n Exhibit 5: Firm resume of Pomerantz.\n\n I declare under penalty of perjury under the laws of the United States of America that the\n\nforegoing facts are true and correct.\n\n Executed on October 6, 2025.\n\n /s/ Jeremy A. Lieberman\n Jeremy A. Lieberman\n\f Case 8:25-cv-02581-TDC Document 14-2 Filed 10/06/25 Page 3 of 3\n\n\n\n CERTIFICATE OF SERVICE\n\n I hereby certify that a true and correct copy of the foregoing was served by the Court\u2019s\n\nCM/ECF system on counsel of record on this 6th day of October, 2025.\n\nDated: October 6, 2025\n\n /s/ Daniel S. Sommers\n Daniel S. Sommers (Md. Bar No. 15822)\n\n\n\n\n 2\n\f","ocr_status":2,"date_upload":"2026-05-18T06:03:52.677226-07:00","document_number":"14","attachment_number":2,"pacer_doc_id":"093015216139","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Declaration of Jeremy A. Lieberman","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528445/","id":479528445,"tags":[],"absolute_url":"/docket/71033169/14/3/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:41.949112-07:00","date_modified":"2026-05-22T03:40:35.160639-07:00","sha1":"6a113a25349efad3865fc0b3674d8ab255b887f4","page_count":2,"file_size":117163,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 14-3 Filed 10/06/25 Page 1 of 2\n\n\n\n UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF MARYLAND\n (Southern Division)\n\n\nDAVE COLLIER, Individually and on Behalf Case No. 8:25-cv-02581-TDC\nof All Others Similarly Situated,\n\n Plaintiff,\n\n v.\n\nALTIMMUNE, INC. et al.,\n\n Defendants.\n\n\n\nINDEX OF EXHIBITS IN SUPPORT OF MOTION OF THE CAO-WU FAMILY AND\n THOMAS RAINWATER FOR APPOINTMENT AS CO-LEAD PLAINTIFFS AND\n APPROVAL OF SELECTION OF COUNSEL\n\f Case 8:25-cv-02581-TDC Document 14-3 Filed 10/06/25 Page 2 of 2\n\n\n\n Cross Reference to\nExhibit Description\n Memorandum\n Chart setting forth the Cao-Wu Family\u2019s and\n 1 Thomas Rainwater\u2019s financial interest in this 1, 6\n litigation.\n\n Press release published via Globe Newswire on\n 2 August 5, 2025, announcing the pendency of the 5\n above-captioned action.\n\n Shareholder Certifications executed by the\n 3 members of the Cao-Wu Family and Thomas 5, 8\n Rainwater.\n\n Joint Declaration executed by the members of\n 4 9\n the Cao-Wu Family and Thomas Rainwater.\n\n 5 Firm resume of Pomerantz LLP. 11-12\n\f","ocr_status":2,"date_upload":"2026-05-18T06:03:57.342251-07:00","document_number":"14","attachment_number":3,"pacer_doc_id":"093015216140","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Index of Exhibits","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528446/","id":479528446,"tags":[],"absolute_url":"/docket/71033169/14/4/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:41.963706-07:00","date_modified":"2026-05-22T03:45:38.442158-07:00","sha1":"a9863e9ebabca91fbc882fd643d0ab5818b92d2e","page_count":5,"file_size":851162,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.4.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 14-4 Filed 10/06/25 Page 1 of 5\n\n\n\n\n EXHIBIT 1\n\n\n\n\n J.R.000001\n\f Case 8:25-cv-02581-TDC Document 14-4 Filed 10/06/25 Page 2 of 5\n\nAltimmune, Inc. (ALT)\nClass Period: August 10, 2023 to June 25, 2025\n(Includes 90-Day Sales @ Statutory Pricing) 90-Days*\n Mean Price\n End-of-Class Post-Class $3.8498\n Purchase or Acquire Sales Shares Shares Estimated Estimated\nPlaintiff Date Shares Price Amount Date Shares Price Amount Retained Retained Value Gain(Loss)\n\n\nSummary\nThomas Rainwater 9,602 ($60,826) (9,602) $34,663 9,602 0 $0 ($26,163)\nYiming Cao, Account 1 4,300 ($27,837) 0 $0 4,300 4,300 $16,554 ($11,283)\nYiming Cao, Account 2 1,000 ($5,450) (1,000) $5,720 0 0 $0 $270\nYaping Wu, Account 1 4,880 ($30,686) (4,880) $20,729 3,880 0 $0 ($9,957)\nYaping Wu, Account 2 1,064 ($7,282) (1,064) $3,783 1,064 0 $0 ($3,500)\nYaping Wu, Account 3 5,433 ($31,799) (5,433) $23,454 4,303 0 $0 ($8,345)\nYaping Wu, Account 4 4,868 ($29,100) (4,868) $19,571 4,868 0 $0 ($9,529)\nYiming Cao and Yaping Wu, Joint Account 5,433 ($33,937) (5,433) $21,842 5,433 0 $0 ($12,095)\nThomas Rainwater; Yiming Cao; Yaping Wu 36,580 ($226,918) (32,280) $129,763 33,450 4,300 $16,554 ($80,602)\n\nThomas Rainwater 11/11/2024 300 $7.0860 ($2,126) 6/26/2025 (9,602) $3.6100 $34,663\nThomas Rainwater 11/13/2024 300 $10.1880 ($3,056)\nThomas Rainwater 12/2/2024 4 $8.6400 ($35)\nThomas Rainwater 12/2/2024 896 $8.6460 ($7,747)\nThomas Rainwater 12/19/2024 300 $8.2459 ($2,474)\nThomas Rainwater 1/16/2025 1,000 $6.7662 ($6,766)\nThomas Rainwater 2/3/2025 300 $6.3858 ($1,916)\nThomas Rainwater 2/18/2025 400 $6.6458 ($2,658)\nThomas Rainwater 2/28/2025 1,000 $6.4958 ($6,496)\nThomas Rainwater 3/4/2025 500 $5.9358 ($2,968)\nThomas Rainwater 4/11/2025 1,000 $4.3658 ($4,366)\nThomas Rainwater 4/30/2025 2,602 $5.2361 ($13,624)\nThomas Rainwater 6/11/2025 1,000 $6.5950 ($6,595)\nThomas Rainwater 9,602 ($60,826) (9,602) $34,663 9,602 0 $0 ($26,163)\n\nAccount 1\nYiming Cao 5/13/2025 1,000 $5.5300 ($5,530)\nYiming Cao 6/10/2025 100 $6.4200 ($642)\nYiming Cao 6/10/2025 100 $6.4200 ($642)\nYiming Cao 6/10/2025 100 $6.4200 ($642)\nYiming Cao 6/10/2025 100 $6.4200 ($642)\nYiming Cao 6/10/2025 100 $6.4200 ($642)\n\n *Avg Closing Prices from June 26, 2025 to September 23, 2025\n J.R.000002\n\f Case 8:25-cv-02581-TDC Document 14-4 Filed 10/06/25 Page 3 of 5\n\nAltimmune, Inc. (ALT)\nClass Period: August 10, 2023 to June 25, 2025\n(Includes 90-Day Sales @ Statutory Pricing) 90-Days*\n Mean Price\n End-of-Class Post-Class $3.8498\n Purchase or Acquire Sales Shares Shares Estimated Estimated\nPlaintiff Date Shares Price Amount Date Shares Price Amount Retained Retained Value Gain(Loss)\nYiming Cao 6/10/2025 100 $6.4200 ($642)\nYiming Cao 6/10/2025 100 $6.4200 ($642)\nYiming Cao 6/10/2025 100 $6.4200 ($642)\nYiming Cao 6/13/2025 500 $6.7700 ($3,385)\nYiming Cao 6/13/2025 500 $6.9800 ($3,490)\nYiming Cao 6/13/2025 700 $7.1200 ($4,984)\nYiming Cao 6/18/2025 300 $6.6400 ($1,992)\nYiming Cao 6/18/2025 500 $6.6400 ($3,320)\nYiming Cao 4,300 ($27,837) 0 $0 4,300 4,300 $16,554 ($11,283)\n\n\nAccount 2\nYiming Cao 6/5/2025 256 $5.4499 ($1,395) 6/9/2025 (1,000) $5.7200 $5,720\nYiming Cao 6/5/2025 744 $5.4499 ($4,055)\nYiming Cao 1,000 ($5,450) (1,000) $5,720 0 0 $0 $270\n\n\nAccount 1\nYaping Wu 6/9/2025 920 $5.7200 ($5,262) 6/17/2025 (1,000) $6.8000 $6,800\nYaping Wu 6/9/2025 900 $5.6700 ($5,103) 6/27/2025 (3,880) $3.5900 $13,929\nYaping Wu 6/9/2025 500 $5.7200 ($2,860)\nYaping Wu 6/9/2025 100 $5.7200 ($572)\nYaping Wu 6/10/2025 310 $6.3900 ($1,981)\nYaping Wu 6/10/2025 245 $6.4000 ($1,568)\nYaping Wu 6/10/2025 105 $6.3900 ($671)\nYaping Wu 6/11/2025 800 $6.8300 ($5,464)\nYaping Wu 6/13/2025 500 $7.1900 ($3,595)\nYaping Wu 6/13/2025 500 $7.2200 ($3,610)\nYaping Wu 4,880 ($30,686) (4,880) $20,729 3,880 0 0 ($9,957)\n\nAccount 2\nYaping Wu 6/13/2025 558 $6.8300 ($3,811) 6/27/2025 (1,064) $3.5550 $3,783\nYaping Wu 6/13/2025 506 $6.8600 ($3,471)\nYaping Wu 1,064 ($7,282) (1,064) $3,783 1,064 0 0 ($3,500)\n\n\n\n\n *Avg Closing Prices from June 26, 2025 to September 23, 2025\n J.R.000003\n\f Case 8:25-cv-02581-TDC Document 14-4 Filed 10/06/25 Page 4 of 5\n\nAltimmune, Inc. (ALT)\nClass Period: August 10, 2023 to June 25, 2025\n(Includes 90-Day Sales @ Statutory Pricing) 90-Days*\n Mean Price\n End-of-Class Post-Class $3.8498\n Purchase or Acquire Sales Shares Shares Estimated Estimated\nPlaintiff Date Shares Price Amount Date Shares Price Amount Retained Retained Value Gain(Loss)\nAccount 3\nYaping Wu 5/23/2025 30 $5.6750 ($170) 5/28/2025 (1,130) $5.4914 $6,205\nYaping Wu 5/23/2025 500 $5.6798 ($2,840) 6/26/2025 (1,000) $3.9700 $3,970\nYaping Wu 5/23/2025 500 $5.6750 ($2,838) 8/11/2025 (82) $4.0203 $330\nYaping Wu 5/23/2025 100 $5.6697 ($567) 8/11/2025 (3,221) $4.0203 $12,949\nYaping Wu 6/6/2025 3 $5.6500 ($17)\nYaping Wu 6/6/2025 1,000 $5.6500 ($5,650)\nYaping Wu 6/9/2025 1,000 $5.7099 ($5,710)\nYaping Wu 6/9/2025 500 $5.6750 ($2,837)\nYaping Wu 6/9/2025 1,000 $5.6894 ($5,689)\nYaping Wu 6/11/2025 100 $6.8600 ($686)\nYaping Wu 6/12/2025 100 $7.1098 ($711)\nYaping Wu 6/16/2025 300 $6.9550 ($2,087)\nYaping Wu 6/18/2025 300 $6.6580 ($1,997)\nYaping Wu 5,433 ($31,799) (5,433) $23,454 4,303 0 $0 ($8,345)\n\nAccount 4\nYaping Wu 5/16/2025 1,000 $5.6400 ($5,640) 8/11/2025 (4,868) $4.0203 $19,571\nYaping Wu 5/16/2025 60 $5.6400 ($338)\nYaping Wu 5/16/2025 1,000 $5.6400 ($5,640)\nYaping Wu 5/16/2025 600 $5.6400 ($3,384)\nYaping Wu 5/23/2025 600 $5.7400 ($3,444)\nYaping Wu 5/30/2025 458 $5.4400 ($2,492)\nYaping Wu 6/13/2025 838 $7.1300 ($5,975)\nYaping Wu 6/16/2025 312 $7.0100 ($2,187)\nYaping Wu 4,868 ($29,100) (4,868) $19,571 4,868 0 $0 ($9,529)\n\nJoint Account\nYiming Cao and Yaping Wu 5/13/2025 900 $5.7500 ($5,175) 8/11/2025 (5,433) $4.0203 $21,842\nYiming Cao and Yaping Wu 5/16/2025 1,000 $5.6400 ($5,640)\nYiming Cao and Yaping Wu 5/23/2025 900 $5.7400 ($5,166)\nYiming Cao and Yaping Wu 5/30/2025 457 $5.4500 ($2,491)\nYiming Cao and Yaping Wu 6/13/2025 280 $7.1200 ($1,994)\nYiming Cao and Yaping Wu 6/13/2025 1,250 $7.1600 ($8,950)\n\n *Avg Closing Prices from June 26, 2025 to September 23, 2025\n J.R.000004\n\f Case 8:25-cv-02581-TDC Document 14-4 Filed 10/06/25 Page 5 of 5\n\nAltimmune, Inc. (ALT)\nClass Period: August 10, 2023 to June 25, 2025\n(Includes 90-Day Sales @ Statutory Pricing) 90-Days*\n Mean Price\n End-of-Class Post-Class $3.8498\n Purchase or Acquire Sales Shares Shares Estimated Estimated\nPlaintiff Date Shares Price Amount Date Shares Price Amount Retained Retained Value Gain(Loss)\nYiming Cao and Yaping Wu 6/16/2025 646 $7.0000 ($4,522)\nYiming Cao and Yaping Wu 5,433 ($33,937) (5,433) $21,842 5,433 0 $0 ($12,095)\n\n\n\n\n *Avg Closing Prices from June 26, 2025 to September 23, 2025\n J.R.000005\n\f","ocr_status":1,"date_upload":"2026-05-18T06:04:05.033981-07:00","document_number":"14","attachment_number":4,"pacer_doc_id":"093015216141","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 1 - Damages Analysis","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528447/","id":479528447,"tags":[],"absolute_url":"/docket/71033169/14/5/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:41.977802-07:00","date_modified":"2026-05-22T03:28:31.838317-07:00","sha1":"7addeb3bb5ef5fd84deab97f8a2073a06d0f2b6a","page_count":3,"file_size":908774,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.5.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.5.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":"2026-05-18T06:04:13.645265-07:00","document_number":"14","attachment_number":5,"pacer_doc_id":"093015216142","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 2 - PSLRA Notice","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528448/","id":479528448,"tags":[],"absolute_url":"/docket/71033169/14/6/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:41.992459-07:00","date_modified":"2026-05-22T03:24:30.694294-07:00","sha1":"f705002fd75ae71a8ded86956786f8ad82ec1d04","page_count":11,"file_size":1096588,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.6.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.6.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 1 of 11\n\n\n\n\n EXHIBIT 3\n\n\n\n\n J.R.000009\n\fDocusign Envelope ID: 171583A9-D0FE-4840-9392-115FF50072D9\n Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 2 of 11\n\n\n\n CERTIFICATION PURSUANT\n TO FEDERAL SECURITIES LAWS\n\n Thomas Rainwater\n 1. I, __________________________________________, make this declaration\n\n pursuant to Section 27(a)(2) of the Securities Act of 1933 (\u201cSecurities Act\u201d) and/or Section\n\n 21D(a)(2) of the Securities Exchange Act of 1934 (\u201cExchange Act\u201d) as amended by the Private\n\n Securities Litigation Reform Act of 1995.\n\n 2. I have reviewed a Complaint against Altimmune, Inc. (\u201cAltimmune\u201d) and authorize\n\n the filing of a comparable complaint on my behalf.\n\n 3. I did not purchase or acquire Altimmune securities at the direction of plaintiffs\u2019\n\n counsel or in order to participate in any private action arising under the Securities Act or Exchange\n\n Act.\n\n 4. I am willing to serve as a representative party on behalf of a Class of investors who\n\n purchased or otherwise acquired Altimmune securities during the Class Period as specified in the\n\n Complaint, including providing testimony at deposition and trial, if necessary. I understand that\n\n the Court has the authority to select the most adequate lead plaintiff in this action.\n\n 5. The attached sheet lists all of my transactions in Altimmune securities during the\n\n Class Period as specified in the Complaint.\n\n 6. During the three-year period preceding the date on which this Certification is\n\n signed, I have not served or sought to serve as a representative party on behalf of a class under the\n\n federal securities laws.\n\n 7. I agree not to accept any payment for serving as a representative party on behalf of\n\n the class as set forth in the Complaint, beyond my pro rata share of any recovery, except such\n\n reasonable costs and expenses directly relating to the representation of the class as ordered or\n\n approved by the Court.\n\n\n\n J.R.000010\n\fDocusign Envelope ID: 171583A9-D0FE-4840-9392-115FF50072D9\n Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 3 of 11\n\n\n\n 8. I declare under penalty of perjury under the laws of the United States of America\n\n that the foregoing is true and correct.\n\n\n\n\n 9/30/2025\n Executed _____________________________\n (Date)\n\n\n\n _______________________________________\n (Signature)\n\n Thomas Rainwater\n _______________________________________\n (Type or Print Name)\n\n\n\n\n J.R.000011\n\f Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 4 of 11\n\n\n\nAltimmune, Inc. (ALT) Thomas Rainwater\n\n List of Purchases/Acquisitions and Sales\n\n Transaction Number of Price Per\n Type Date Shares/Unit Share/Unit\n\n Purchase/Acquisition 11/11/2024 300 $7.0860\n Purchase/Acquisition 11/13/2024 300 $10.1880\n Purchase/Acquisition 12/2/2024 4 $8.6400\n Purchase/Acquisition 12/2/2024 896 $8.6460\n Purchase/Acquisition 12/19/2024 300 $8.2459\n Purchase/Acquisition 1/16/2025 1,000 $6.7662\n Purchase/Acquisition 2/3/2025 300 $6.3858\n Purchase/Acquisition 2/18/2025 400 $6.6458\n Purchase/Acquisition 2/28/2025 1,000 $6.4958\n Purchase/Acquisition 3/4/2025 500 $5.9358\n Purchase/Acquisition 4/11/2025 1,000 $4.3658\n Purchase/Acquisition 4/30/2025 2,602 $5.2361\n Purchase/Acquisition 6/11/2025 1,000 $6.5950\n\n\n\n\n J.R.000012\n\fDocusign Envelope ID: 10A8618A-F9E4-4806-BD67-941C13C8C9C4\n Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 5 of 11\n\n\n\n CERTIFICATION PURSUANT\n TO FEDERAL SECURITIES LAWS\n\n\n 1. I, Yiming Cao, make this declaration pursuant to Section 27(a)(2) of the Securities\n\n Act of 1933 (\u201cSecurities Act\u201d) and/or Section 21D(a)(2) of the Securities Exchange Act of 1934\n\n (\u201cExchange Act\u201d) as amended by the Private Securities Litigation Reform Act of 1995.\n\n 2. I have reviewed a Complaint against Altimmune, Inc. (\u201cAltimmune\u201d) and authorize\n\n the filing of a comparable complaint on my behalf.\n\n 3. I did not purchase or acquire Altimmune securities at the direction of plaintiffs\u2019\n\n counsel or in order to participate in any private action arising under the Securities Act or Exchange\n\n Act.\n\n 4. I am willing to serve as a representative party on behalf of a Class of investors who\n\n purchased or otherwise acquired Altimmune securities during the Class Period as specified in the\n\n Complaint, including providing testimony at deposition and trial, if necessary. I understand that\n\n the Court has the authority to select the most adequate lead plaintiff in this action.\n\n 5. The attached sheet lists all of my transactions in Altimmune securities during the\n\n Class Period as specified in the Complaint.\n\n 6. During the three-year period preceding the date on which this Certification is\n\n signed, I have not served or sought to serve as a representative party on behalf of a class under the\n\n federal securities laws.\n\n 7. I agree not to accept any payment for serving as a representative party on behalf of\n\n the Class as set forth in the Complaint, beyond my pro rata share of any recovery, except such\n\n reasonable costs and expenses directly relating to the representation of the class as ordered or\n\n approved by the Court.\n\n 8. I declare under penalty of perjury under the laws of the United States of America\n\n\n\n J.R.000013\n\fDocusign Envelope ID: 10A8618A-F9E4-4806-BD67-941C13C8C9C4\n Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 6 of 11\n\n\n\n that the foregoing is true and correct.\n\n\n\n\n 10/3/2025\n Executed ________________\n (Date)\n\n\n\n _______________________________________\n (Signature)\n\n\n _Yiming Cao________________\n (Type or Print Name)\n\n\n\n\n J.R.000014\n\f Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 7 of 11\n\n\n\nAltimmune, Inc. (ALT) Yiming Cao\n\n List of Purchases/Acquisitions and Sales\n\n Transaction Number of Price Per\n Type Date Shares/Unit Share/Unit\n\n Account 1\n Purchase/Acquisition 5/13/2025 1,000 $5.5300\n Purchase/Acquisition 6/10/2025 100 $6.4200\n Purchase/Acquisition 6/10/2025 100 $6.4200\n Purchase/Acquisition 6/10/2025 100 $6.4200\n Purchase/Acquisition 6/10/2025 100 $6.4200\n Purchase/Acquisition 6/10/2025 100 $6.4200\n Purchase/Acquisition 6/10/2025 100 $6.4200\n Purchase/Acquisition 6/10/2025 100 $6.4200\n Purchase/Acquisition 6/10/2025 100 $6.4200\n Purchase/Acquisition 6/13/2025 500 $6.7700\n Purchase/Acquisition 6/13/2025 500 $6.9800\n Purchase/Acquisition 6/13/2025 700 $7.1200\n Purchase/Acquisition 6/18/2025 300 $6.6400\n Purchase/Acquisition 6/18/2025 500 $6.6400\n\n Account 2\n Purchase/Acquisition 6/5/2025 256 $5.4499\n Purchase/Acquisition 6/5/2025 744 $5.4499\n Sale 6/9/2025 (1,000) $5.7200\n\n Joint Account\n Purchase/Acquisition 5/13/2025 900 $5.7500\n Purchase/Acquisition 5/16/2025 1,000 $5.6400\n Purchase/Acquisition 5/23/2025 900 $5.7400\n Purchase/Acquisition 5/30/2025 457 $5.4500\n Purchase/Acquisition 6/13/2025 280 $7.1200\n Purchase/Acquisition 6/13/2025 1,250 $7.1600\n Purchase/Acquisition 6/16/2025 646 $7.0000\n\n\n\n\n J.R.000015\n\fDocusign Envelope ID: 10A8618A-F9E4-4806-BD67-941C13C8C9C4\n Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 8 of 11\n\n\n\n CERTIFICATION PURSUANT\n TO FEDERAL SECURITIES LAWS\n\n\n 1. I, Yaping Wu, make this declaration pursuant to Section 27(a)(2) of the Securities\n\n Act of 1933 (\u201cSecurities Act\u201d) and/or Section 21D(a)(2) of the Securities Exchange Act of 1934\n\n (\u201cExchange Act\u201d) as amended by the Private Securities Litigation Reform Act of 1995.\n\n 2. I have reviewed a Complaint against Altimmune, Inc. (\u201cAltimmune\u201d) and authorize\n\n the filing of a comparable complaint on my behalf.\n\n 3. I did not purchase or acquire Altimmune securities at the direction of plaintiffs\u2019\n\n counsel or in order to participate in any private action arising under the Securities Act or Exchange\n\n Act.\n\n 4. I am willing to serve as a representative party on behalf of a Class of investors who\n\n purchased or otherwise acquired Altimmune securities during the Class Period as specified in the\n\n Complaint, including providing testimony at deposition and trial, if necessary. I understand that\n\n the Court has the authority to select the most adequate lead plaintiff in this action.\n\n 5. The attached sheet lists all of my transactions in Altimmune securities during the\n\n Class Period as specified in the Complaint.\n\n 6. During the three-year period preceding the date on which this Certification is\n\n signed, I have not served or sought to serve as a representative party on behalf of a class under the\n\n federal securities laws.\n\n 7. I agree not to accept any payment for serving as a representative party on behalf of\n\n the Class as set forth in the Complaint, beyond my pro rata share of any recovery, except such\n\n reasonable costs and expenses directly relating to the representation of the class as ordered or\n\n approved by the Court.\n\n 8. I declare under penalty of perjury under the laws of the United States of America\n\n\n\n J.R.000016\n\fDocusign Envelope ID: 10A8618A-F9E4-4806-BD67-941C13C8C9C4\n Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 9 of 11\n\n\n\n that the foregoing is true and correct.\n\n\n\n\n 10/3/2025\n Executed ________________\n (Date)\n\n\n\n _______________________________________\n (Signature)\n\n\n _Yaping Wu________________\n (Type or Print Name)\n\n\n\n\n J.R.000017\n\f Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 10 of 11\n\n\n\nAltimmune, Inc. (ALT) Yaping Wu\n\n List of Purchases/Acquisitions and Sales\n\n Transaction Number of Price Per\n Type Date Shares/Unit Share/Unit\n\n Account 1\n Purchase/Acquisition 6/9/2025 920 $5.7200\n Purchase/Acquisition 6/9/2025 900 $5.6700\n Purchase/Acquisition 6/9/2025 500 $5.7200\n Purchase/Acquisition 6/9/2025 100 $5.7200\n Purchase/Acquisition 6/10/2025 310 $6.3900\n Purchase/Acquisition 6/10/2025 245 $6.4000\n Purchase/Acquisition 6/10/2025 105 $6.3900\n Purchase/Acquisition 6/11/2025 800 $6.8300\n Purchase/Acquisition 6/13/2025 500 $7.1900\n Purchase/Acquisition 6/13/2025 500 $7.2200\n Sale 6/17/2025 (1,000) $6.8000\n\n Account 2\n Purchase/Acquisition 6/13/2025 558 $6.8300\n Purchase/Acquisition 6/13/2025 506 $6.8600\n\n Account 3\n Purchase/Acquisition 5/23/2025 30 $5.6750\n Purchase/Acquisition 5/23/2025 500 $5.6798\n Purchase/Acquisition 5/23/2025 500 $5.6750\n Purchase/Acquisition 5/23/2025 100 $5.6697\n Purchase/Acquisition 6/6/2025 3 $5.6500\n Purchase/Acquisition 6/6/2025 1,000 $5.6500\n Purchase/Acquisition 6/9/2025 1,000 $5.7099\n Purchase/Acquisition 6/9/2025 500 $5.6750\n Purchase/Acquisition 6/9/2025 1,000 $5.6894\n Purchase/Acquisition 6/11/2025 100 $6.8600\n Purchase/Acquisition 6/12/2025 100 $7.1098\n Purchase/Acquisition 6/16/2025 300 $6.9550\n Purchase/Acquisition 6/18/2025 300 $6.6580\n Sale 5/28/2025 (1,130) $5.4914\n\n Account 4\n Purchase/Acquisition 5/16/2025 1,000 $5.6400\n Purchase/Acquisition 5/16/2025 60 $5.6400\n Purchase/Acquisition 5/16/2025 1,000 $5.6400\n Purchase/Acquisition 5/16/2025 600 $5.6400\n Purchase/Acquisition 5/23/2025 600 $5.7400\n Purchase/Acquisition 5/30/2025 458 $5.4400\n Purchase/Acquisition 6/13/2025 838 $7.1300\n Purchase/Acquisition 6/16/2025 312 $7.0100\n\n Joint Account\n Purchase/Acquisition 5/13/2025 900 $5.7500\n Purchase/Acquisition 5/16/2025 1,000 $5.6400\n Purchase/Acquisition 5/23/2025 900 $5.7400\n Purchase/Acquisition 5/30/2025 457 $5.4500\n Purchase/Acquisition 6/13/2025 280 $7.1200\n Purchase/Acquisition 6/13/2025 1,250 $7.1600\n\n\n\n\n J.R.000018\n\f Case 8:25-cv-02581-TDC Document 14-6 Filed 10/06/25 Page 11 of 11\n\n\n\nAltimmune, Inc. (ALT) Yaping Wu\n\n List of Purchases/Acquisitions and Sales\n\n Transaction Number of Price Per\n Type Date Shares/Unit Share/Unit\n\n Purchase/Acquisition 6/16/2025 646 $7.0000\n\n\n\n\n J.R.000019\n\f","ocr_status":1,"date_upload":"2026-05-18T06:04:21.512266-07:00","document_number":"14","attachment_number":6,"pacer_doc_id":"093015216143","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 3 - Shareholder Certifications","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528449/","id":479528449,"tags":[],"absolute_url":"/docket/71033169/14/7/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:42.007704-07:00","date_modified":"2026-05-22T03:48:38.175827-07:00","sha1":"70e4b09e3c6f7cc810f8cd850091456fc543d277","page_count":8,"file_size":1030403,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.7.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.7.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 14-7 Filed 10/06/25 Page 1 of 8\n\n\n\n\n EXHIBIT 4\n\n\n\n\n J.R.000020\n\f Case 8:25-cv-02581-TDC Document 14-7 Filed 10/06/25 Page 2 of 8\n\n\n\n\n JOINT DECLARATION IN SUPPORT OF LEAD PLAINTIFF MOTION\n\n We, the undersigned, pursuant to 28 U.S.C. \u00a7 1746, declare as follows:\n\n 1. We, Yiming Cao, Yaping Wu, and Thomas Rainwater, respectfully submit this Joint\n\nDeclaration in support of our motion for appointment as Co-Lead Plaintiffs and approval of our\n\nselection of Pomerantz LLP (\u201cPomerantz\u201d) as Lead Counsel in the instant class action on behalf\n\nof investors in the securities of Altimmune, Inc. (\u201cAltimmune\u201d) pursuant to the Private Securities\n\nLitigation Reform Act of 1995 (the \u201cPSLRA\u201d). We are informed of and understand the\n\nrequirements and duties imposed by the PSLRA. We each have personal knowledge about the\n\ninformation in this Joint Declaration.\n\n 2. I, Yiming Cao, live in Philadelphia, Pennsylvania. In addition to Pomerantz, I am\n\nalso represented by the Bronstein, Gewirtz & Grossman, LLC (\u201cBG&G\u201d) law firm in this action.\n\nYaping Wu is my wife. I have a master\u2019s degree in biostatistics and am a statistical computer\n\nprogrammer. I have prior experience working with attorneys. I am 32 years old and have been\n\ninvesting in the securities markets for 5 years. As reflected in my Certification, I purchased\n\nAltimmune securities during the Class Period and suffered substantial losses as a result of the\n\nviolations of the federal securities laws alleged in this action.\n\n 3. I, Yaping Wu, live in Philadelphia, Pennsylvania. In addition to Pomerantz, I am\n\nalso represented by the BG&G law firm in this action. Yiming Cao is my husband. I have an\nassociate\u2019s degree in paralegal studies and am currently a homemaker, prior to which I worked as\n\na paralegal. I have prior experience working with attorneys. I am 32 years old and have been\n\ninvesting in the securities markets for 6 years. As reflected in my Certification, I purchased\n\nAltimmune securities during the Class Period and suffered substantial losses as a result of the\n\nviolations of the federal securities laws alleged in this action.\n\n 4. I, Thomas Rainwater, live in Santa Fe, Texas. I am retired, prior to which I worked\n\nin refinery operations. I am 66 years old and have been investing in the securities markets for 10\n\nyears. As reflected in my Certification, I purchased Altimmune securities during the Class Period\n\n\n\n\n J.R.000021\n\f Case 8:25-cv-02581-TDC Document 14-7 Filed 10/06/25 Page 3 of 8\n\n\n\n\nand suffered substantial losses as a result of the violations of the federal securities laws alleged in\n\nthis action.\n\n 5. We have discussed this case with each other and our counsel. Accordingly, each of\n\nus is aware of the current status of this litigation. We understand that, in addition to ourselves,\n\nother investors in Altimmune securities may file motions seeking appointment as Lead Plaintiff in\n\nthis action. We understand that on October 6, 2025, our counsel will file a memorandum of law\n\nin support of our motion for appointment as Co-Lead Plaintiffs. We understand that this Joint\n\nDeclaration and other supporting submissions prepared by our counsel will be filed concurrently\n\nwith the memorandum of law. We understand that the Lead Plaintiff role includes evaluating the\n\nstrengths and weaknesses of the case and prospects for resolution of this matter. We understand\n\nthat it is the Lead Plaintiff\u2019s responsibility to direct counsel with respect to this litigation, after\n\nreceiving the benefit of counsel\u2019s advice. We approved Pomerantz as our designated Lead\n\nCounsel. We participated in a conference call with each other and an attorney from Pomerantz to\n\ndiscuss this litigation, have one another\u2019s contact information, and approved the filing of a motion\n\non our behalves seeking appointment jointly as Co-Lead Plaintiffs.\n\n 6. We attest to, among other things, our shared belief in the merits of this action; our\n\nshared desire to achieve the best possible result for the Class; our shared interest in prosecuting\n\nthe case in a collaborative and likeminded manner; our understanding of the fiduciary obligations\nof Lead Plaintiffs; and our preparedness to supervise counsel and undertake all actions necessary\n\nto ensure that the Class\u2019s claims will be zealously and efficiently litigated. We hereby affirm that\n\nthe foregoing statements, as well as all other statements set forth in this Joint Declaration, are true\n\nand correct statements of our views and intentions with respect to this litigation, and that we seek\n\nappointment as Co-Lead Plaintiffs in this action.\n\n 7. Given our significant financial interest in the claims against the defendants, we are\n\nstrongly motivated to recover the significant losses that we and the Class suffered as a result of\n\ndefendants\u2019 violations of the federal securities laws. Our principal goal in seeking to serve as Co-\nLead Plaintiffs in this case is to achieve the best possible recovery for the Class from all culpable\n\n\n\n J.R.000022\n\f Case 8:25-cv-02581-TDC Document 14-7 Filed 10/06/25 Page 4 of 8\n\n\n\n\nparties. We are committed to ensuring the litigation is litigated as zealously and efficiently as\n\npossible, in accordance with our duties under the PSLRA.\n\n 8. If appointed Co-Lead Plaintiffs, we will satisfy our fiduciary obligations to the\n\nClass by, among other steps, conferring with each other and with our counsel regarding litigation\n\nstrategy and other matters, attending court proceedings, depositions, any settlement mediations,\n\nand hearings as needed, and reviewing and authorizing the filing of important litigation documents.\n\nThrough these and other measures, we will ensure that the Altimmune securities litigation will be\n\nvigorously prosecuted consistent with the obligations of Lead Plaintiffs under the PSLRA and in\n\nthe best interests of the Class, and will seek to obtain the greatest possible recovery for the Class.\n\n 9. We understand that the Lead Plaintiff\u2019s share of any recovery is the same as every\n\nother potential Class member. As our respective Certifications state, we will not accept any\n\npayment for serving as a representative party beyond our pro rata share, except any reasonable\n\ncosts and expenses directly related to the Class representation as ordered or approved by the Court\n\npursuant to the PSLRA.\n\n 10. We each determined that we could maximize the Class\u2019s recovery by pooling our\n\nrespective resources and experience by jointly seeking appointment as Co-Lead Plaintiffs. After\n\nreviewing the allegations pleaded in the complaint, and consulting with each other and our counsel,\n\nwe each independently determined to seek joint appointment as Co-Lead Plaintiffs, and\nsubsequently approved the filing of a joint motion seeking our appointment as Co-Lead Plaintiffs.\n\nWe agree that our collective resources and our ability to engage in joint decision-making will\n\nmaterially benefit and advance the interests of the Class in this case.\n\n 11. We do not anticipate that any disagreements between us will arise and agree to\n\nmake all efforts, in good faith, to reach consensus with respect to all litigation decisions, and to\n\nthat end will consult with our counsel as we deem necessary to fulfill our fiduciary obligations to\n\nthe Class. In the event that such a disagreement arises, we agree to resolve such disagreement by\n\na majority vote, in which each of us possesses a number of votes equal to our losses incurred in\nconnection with our Class Period transactions in Altimmune securities, calculated in terms of U.S.\n\n\n\n J.R.000023\n\f Case 8:25-cv-02581-TDC Document 14-7 Filed 10/06/25 Page 5 of 8\n\n\n\n\ndollars. We recognize that even in the event of such a disagreement, the ultimate decision will\n\nnecessarily be informed by consulting one another and our counsel.\n\n 12. We understand that the PSLRA and courts throughout the country, including courts\n\nin this District, have endorsed the appointment of small groups of investors to serve as Co-Lead\n\nPlaintiffs when the group establishes that its members can oversee the litigation and their proposed\n\nLead Counsel in an independent manner. We intend to prosecute this litigation in such an\n\nindependent and vigorous manner.\n\n 13. We also understand and appreciate the Lead Plaintiff\u2019s obligation under the PSLRA\n\nto select Lead Counsel and to monitor the action to ensure it is prosecuted efficiently. We have\n\nfulfilled this responsibility by selecting and retaining Lead Counsel with a proven history of\n\nhandling this type of complex litigation. In this case, we selected Pomerantz to serve as Lead\n\nCounsel. Based on Pomerantz\u2019s experience in achieving substantial recoveries in securities class\n\nactions, we believe that the firm is well-qualified to represent the Class.\n\n 14. Pomerantz has been directed to prosecute this action in an efficient, cost-effective\n\nmanner while obtaining the best possible result for the Class. We will continue to supervise\n\ncounsel and actively oversee the prosecution of the action for the benefit of the Class by, among\n\nother things, reviewing pleadings, instructing counsel, and/or attending hearings, as necessary.\n\n\n\n\n J.R.000024\n\fDocusign Envelope ID: 10A8618A-F9E4-4806-BD67-941C13C8C9C4\n Case 8:25-cv-02581-TDC Document 14-7 Filed 10/06/25 Page 6 of 8\n\n\n\n Pursuant to 28 U.S.C. \u00a7 1746, I declare under penalty of perjury under the laws of the United States\n of America that the foregoing statements relating to myself are true and correct to the best of my\n knowledge.\n\n 3rd\n Executed on this __________ day of October, 2025.\n\n\n _________________________\n\n Yiming Cao\n\n\n\n\n J.R.000025\n\fDocusign Envelope ID: 10A8618A-F9E4-4806-BD67-941C13C8C9C4\n Case 8:25-cv-02581-TDC Document 14-7 Filed 10/06/25 Page 7 of 8\n\n\n\n Pursuant to 28 U.S.C. \u00a7 1746, I declare under penalty of perjury under the laws of the United States\n of America that the foregoing statements relating to myself are true and correct to the best of my\n knowledge.\n\n 3rd\n Executed on this __________ day of October, 2025.\n\n\n _________________________\n\n Yaping Wu\n\n\n\n\n J.R.000026\n\fDocusign Envelope ID: 4398E58F-0DCF-401A-A91A-F81C36BBD7CF\n Case 8:25-cv-02581-TDC Document 14-7 Filed 10/06/25 Page 8 of 8\n\n\n\n Pursuant to 28 U.S.C. \u00a7 1746, I declare under penalty of perjury under the laws of the United States\n of America that the foregoing statements relating to myself are true and correct to the best of my\n knowledge.\n 6\n Executed on this __________ day of October, 2025.\n\n\n _________________________\n\n Thomas Rainwater\n\n\n\n\n J.R.000027\n\f","ocr_status":1,"date_upload":"2026-05-18T06:04:25.475239-07:00","document_number":"14","attachment_number":7,"pacer_doc_id":"093015216144","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 4 - Joint Declaration","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528450/","id":479528450,"tags":[],"absolute_url":"/docket/71033169/14/8/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:42.022962-07:00","date_modified":"2026-05-22T03:47:23.227826-07:00","sha1":"d878a98cd5d94b15a16a1a2d25a1f625f2ff25c2","page_count":9,"file_size":1284780,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.8.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.8.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 1 of 9\n\n\n\n\n EXHIBIT 5\n\n\n\n\n J.R.000028\n\f Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 2 of 9\n\n\n\n\nHistory Pomerantz LLP is one of the most respected law firms in the United States dedicated\nto representing investors. The Firm was founded in 1936 by the late Abraham L. Pomerantz,\nwidely regarded as a legal pioneer and \u201cdean\u201d of the plaintiffs\u2019 securities bar, who helped secure\nthe right of investors to bring class and derivative actions.\n\nLeadership Today, led by Managing Partner Jeremy A. Lieberman, the Firm maintains the\ncommitments to excellence and integrity passed down by Abe Pomerantz.\n\nResults Pomerantz achieved a historic $3 billion settlement for defrauded investors in 2018\nas well as precedent-setting legal rulings, in In re Petrobras Securities Litigation. Pomerantz\nconsistently shapes the law, winning landmark decisions that expand and protect investor rights\nand initiating historic corporate governance reforms.\n\nGlobal Expertise Beyond its three American offices, the Firm has offices in Paris,\nLondon, and Tel Aviv. Pomerantz also partners with an extensive network of prominent law\nfirms across the globe to assist clients, wherever they are situated, in recovering monies lost due\nto corporate misconduct and securities fraud. Our team of attorneys is collectively fluent in\nEnglish, Arabic, Cantonese, Mandarin, French, Hebrew, Italian, Portuguese, Romanian, Russian,\nSpanish, and Ukrainian.\n\nPractice Pomerantz protects, expands, and vindicates shareholder rights through our\nsecurities litigation services and portfolio monitoring service. The Firm represents some of the\nlargest and most influential pension funds, asset managers and institutional investors around\nthe globe, monitoring assets of over $9.4 trillion and growing. Pomerantz\u2019s practice includes\ncorporate governance, antitrust, and strategic consumer litigation.\n\nRecognition Pomerantz has been recognized as a top tier firm by The Legal 500,\nBenchmark Litigation, and Chambers USA, among others. In 2020, Pomerantz was named the\nPlaintiff Firm of the Year by Benchmark Litigation and honored with European Pensions\u2019\ninaugural Thought Leadership Award. Courts across the country have noted the quality of our\nlegal work, and Pomerantz attorneys regularly receive praise from their peers. The 2024\nBenchmark Litigation guide describes Pomerantz\u2019s \u201cprodigious capacity for cases and its tenacity\nto keep pursuing them\u201d as well as the Firm\u2019s work on litigation \u201cwith more meaningful angles.\u201d\nThe Firm\u2019s attorneys have been recognized by major industry publications, including The\nNational Law Journal, The New York Law Journal, Law360, and Lawdragon. Among the\nprestigious honors received by Pomerantz attorneys are the Benchmark Litigation Plaintiff\nLitigator of the Year Award (Jeremy Lieberman, 2019; Emma Gilmore 2024), New York Law\nJournal Innovation Award (Jennifer Pafiti, 2023), and Law360 Titan of the Plaintiffs Bar (Murielle\nSteven Walsh, 2024).\n\n Pomerantz is headquartered in New York City, with offices in\n Chicago, Los Angeles, London, Paris, and Tel Aviv.\n\n\n\nwww.pomlaw.com 1\n\n J.R.000029\n\f Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 3 of 9\n\n\n\n Securities Litigation\n Significant Landmarks\n\nIn re Petrobras Sec. Litig., No. 14-cv-9662 (S.D.N.Y. 2018)\nOn January 3, 2018, in a significant victory for investors, Pomerantz, as sole Lead Counsel for the class,\nalong with Lead Plaintiff Universities Superannuation Scheme Limited (\u201cUSS\u201d), achieved a historic $2.95\nbillion settlement with Petr\u00f3leo Brasileiro S.A. (\u201cPetrobras\u201d) and its related entity, Petrobras\nInternational Finance Company, as well as certain of Petrobras\u2019 former executives and directors. On\nFebruary 2, 2018, Pomerantz and USS reached a $50 million settlement with Petrobras\u2019 auditors,\nPricewaterhouseCoopers Auditores Independentes, bringing the total recovery for Petrobras investors\nto $3 billion.\n\nThis is not only the largest securities class action settlement in a decade but is the largest settlement\never in a securities class action involving a foreign issuer, the fifth-largest securities class action\nsettlement ever achieved in the United States, the largest securities class action settlement achieved by\na foreign Lead Plaintiff, and the largest securities class action settlement in history not involving a\nrestatement of financial reports.\n\nThe class action, brought on behalf of all purchasers of common and preferred American Depositary\nShares (\u201cADSs\u201d) on the New York Stock Exchange, as well as purchasers of certain Petrobras debt,\nprincipally alleged that Petrobras and its senior executives engaged in a multi-year, multi-billion-dollar\nmoney-laundering and bribery scheme, which was concealed from investors.\n\nIn addition to the multi-billion-dollar recovery for defrauded investors, Pomerantz secured precedent-\nsetting decisions when the Second Circuit Court of Appeals squarely rejected defendants\u2019 invitation to\nadopt the heightened ascertainability requirement promulgated by the Third Circuit, which would have\nrequired plaintiffs to demonstrate that determining membership in a class is \u201cadministratively feasible.\u201d\nThe Second Circuit\u2019s rejection of this standard is not only a victory for bondholders in securities class\nactions, but also for plaintiffs in consumer fraud class actions and other class actions where\ndocumentation regarding Class membership is not readily attainable. The Second Circuit also refused to\nadopt a requirement, urged by defendants, that all securities class action plaintiffs seeking class\ncertification prove through direct evidence (i.e., an event study) that the prices of the relevant securities\nmoved in a particular direction in response to new information.\n\nPirnik v. Fiat Chrysler Automobiles N.V. et al., No. 1:15-cv-07199-JMF (S.D.N.Y)\nIn August 2019, Pomerantz, as Lead Counsel, achieved final approval of a $110 million settlement for the\nClass in this high-profile securities class action. Plaintiffs alleged that Fiat Chrysler concealed from\ninvestors that it improperly outfitted its diesel vehicles with \u201cdefeat device\u201d software designed to cheat\nNOx emissions regulations in the U.S. and Europe, and that regulators had accused Fiat Chrysler of\nviolating the emissions regulations. The Fiat Chrysler recovery provides the class of investors with as\nmuch as 20% of recoverable damages\u2014an excellent result when compared to historical statistics in class\naction settlements, where typical recoveries for cases of this size are between 1.6% and 3.3%.\n\n\n\n\nwww.pomlaw.com 2\n\n\n J.R.000030\n\f Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 4 of 9\n\n\n\nIn addition to creating precedent-setting case law in successfully defending the various motions to\ndismiss the Fiat Chrysler litigation, Pomerantz also significantly advanced investors\u2019 ability to obtain\ncritically important discovery from regulators that are often at the center of securities actions. During\nthe litigation, Pomerantz sought the deposition of a former employee of the National Highway Traffic\nSafety Administration (\u201cNHTSA\u201d). The United States Department of Transportation (\u201cUSDOT\u201d), like most\nfederal agencies, has enacted a set of regulations\u2014known as \u201cTouhy regulations\u201d\u2014governing when its\nemployees may be called by private parties to testify in court. On their face, USDOT\u2019s regulations apply\nto both \u201ccurrent\u201d and \u201cformer\u201d employees. In response to Pomerantz\u2019s request to depose a former\nemployee of NHSTA that interacted with Fiat Chrysler, NHTSA denied the request, citing the Touhy\nregulation. Despite the widespread application, and assumed appropriateness, of applying these\nregulations to former employees throughout the case law, Pomerantz filed an action against USDOT and\nNHTSA, arguing that the statute pursuant to which the Touhy regulations were enacted speaks only of\n\u201cemployees,\u201d which should be interpreted to apply only to current employees. The court granted\nsummary judgment in favor of Pomerantz\u2019s clients, holding that \u201cUSDOT\u2019s Touhy regulations are\nunlawful to the extent that they apply to former employees.\u201d This victory will greatly shift the discovery\ntools available, so that investor plaintiffs in securities class actions against highly regulated entities (for\nexample, companies subject to FDA regulations) will now be able to depose former employees of the\nregulators that interacted with the defendants during the class period to get critical testimony\nconcerning the company\u2019s violations and misdeeds.\n\nKarimi v. Deutsche Bank AG, 1:22-cv-02854 (S.D.N.Y.)\n\nOn September 27, 2022, Pomerantz reached a $26.25 million settlement on behalf of defrauded\ninvestors in a securities class action against Deutsche Bank AG. The settlement represents over 49% of\nestimated recoverable damages, far in excess of the 1.8% median recovery in similar cases.\n\nThe complaint alleges that Deutsche Bank failed to properly adhere to its own Know Your Customer\n(\u201cKYC\u201d) policies when dealing with customers it considered high-risk, such as accused sex offender\nJeffrey Epstein, Russian oligarchs and politically exposed persons (\u201cPEPs\u201d) reportedly engaged in criminal\nactivities. The Bank repeatedly assured investors that it had \u201cdeveloped effective procedures for\nassessing clients and processes for accepting new clients in order to facilitate comprehensive\ncompliance\u201d with these policies. In reality, however, during the Class Period, defendants repeatedly\nexempted high net-worth individuals and PEPs from any meaningful due diligence, further enabling their\ncrimes through the use of the Bank\u2019s facilities.\n\nFor example, in 2013, Deutsche Bank took on Jeffrey Epstein as a client, despite his previous convictions\nfor and new allegations of child sex trafficking and abuse. Because Epstein was regarded as a \u201chigh-risk\u201d\ncustomer, he should have been subject to the strict due diligence required by the Bank\u2019s KYC program;\nhowever, he was instead classified as an \u201cHonorary PEP,\u201d and his activities within the Bank were allowed\nto continue, largely due to the business he could generate for the Bank. Prior to his onboarding as a\nclient, \u201c40 underage girls had come forward with testimony of Epstein sexually assaulting them,\u201d and\ndespite these allegations, Deutsche Bank remained \u201ccomfortable with things continuing.\u201d\n\n\n\n\nwww.pomlaw.com 3\n\n\n J.R.000031\n\f Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 5 of 9\n\n\n\nHoward v. Arconic et al., No. 2:17-cv-01057 (W.D.Pa.)\n\nIn August 2023, Pomerantz, as Co-Lead Counsel, achieved final approval of a $74 million settlement on\nbehalf of defrauded investors in a securities class action against the American industrial company\nArconic.\n\nOn June 14, 2017, a devastating fire broke out in the Grenfell Tower block of flats in London, United\nKingdom, resulting in the deaths of 72 people and injuries to more than 70 other tenants. In the wake of\nthe tragedy, numerous investigations were conducted, ultimately revealing that, while an electrical fault\nwithin the building instigated the blaze, Arconic\u2019s Reynobond PE panels, which covered the outside of\nthe building, likely acted as an accelerant, contributing to the rapid spread of the flames to the floors\nabove.\n\nIn August 2017, Pomerantz filed a securities class action against Arconic alleging that its stock price was\nartificially inflated during the Class Period by the company\u2019s misstatements about the safety of its\nReynobond PE insulating panels. Following a partial dismissal, Pomerantz filed a second amended\ncomplaint, which cited numerous instances in which Arconic sold Reynobond PE panels for use in other\nhigh-rise towers in the UK and across the globe.\n\nNotably, despite the United States\u2019 near universal ban of combustible Reynobond for buildings taller\nthan twelve meters (40 feet), plaintiffs found that Arconic had sold these panels for use in the\nconstruction of numerous structures measuring twelve meters or higher throughout the country,\nincluding a terminal at the Dallas/Fort Worth airport and Ohio\u2019s Cleveland Browns stadium. The\ncomplaint also pointed to at least eighteen other instances in which deadly fires had spread through\nexterior wall assemblies, most of which involved high-rise buildings. The new allegations included in the\nsecond amended complaint convinced Chief U.S. District Judge Mark R. Hornak to not only change his\nmind on many of the claims he had previously dismissed, but also to make new law in plaintiffs favor on\nseveral significant issues, including the element of scienter, i.e., intent to deceive investors.\n\nThe $74 million settlement represents approximately 22% of recoverable damages for defrauded\nArconic shareholders, an amount far exceeding the 1.8% median recovery for all securities class action\nsettlements in 2022.\n\nKaplan v. S.A.C. Capital Advisors, L.P, No. 12-cv-9350 (S.D.N.Y.)\nIn May 2017, Pomerantz, as Co-Lead Counsel, achieved final approval of a $135 million recovery for the\nClass in this securities class action that stemmed from what has been called the most profitable insider\ntrading scheme in U.S. history. After years of vigorous litigation, billionaire Steven A. Cohen's former\nhedge fund, S.A.C. Capital Advisors LP, agreed to settle the lawsuit by investors in the drug maker Elan\nCorp, who said they lost money because of insider trading by one of his portfolio managers.\n\nIn re BP p.l.c. Securities Litigation, MDL No. 2185 (S.D. Tex.)\nBeginning in 2012, Pomerantz pursued ground-breaking individual lawsuits for institutional investors to\nrecover losses in BP p.l.c.\u2019s London-traded common stock and NYSE-traded American Depository Shares\n(ADSs) arising from its 2010 Gulf of Mexico oil spill. Over nine years, Pomerantz briefed and argued\nevery significant dispute on behalf of 125+ institutional plaintiffs, successfully opposed three motions to\n\n\nwww.pomlaw.com 4\n\n\n J.R.000032\n\f Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 6 of 9\n\n\n\ndismiss, won other contested motions, oversaw e-discovery of 1.75 million party and non-party\ndocuments, led the Individual Action Plaintiffs Steering Committee, served as sole Liaison with BP and\nthe Court, and worked tirelessly with our clients\u2019 outside investment management firms to develop\ncrucial case evidence.\n\nA threshold challenge was how to litigate in U.S. court given the U.S. Supreme Court\u2019s decision in\nMorrison v. National Australia Bank, 130 S. Ct. 2869 (2010), which barred recovery for losses in foreign-\ntraded securities under the U.S. federal securities laws. In 2013 and 2014, Pomerantz won significant\nvictories in defeating BP\u2019s forum non conveniens arguments, which sought to force dismissal of the\nEnglish common law claims from U.S. courts for refiling in English courts, first as regards U.S. institutions\nand, later, foreign institutions. Pomerantz also defeated BP\u2019s attempt to extend the U.S. federal\nSecurities Litigation Uniform Standards Act of 1998 to reach, and dismiss, these foreign law claims in\ndeference to non-existent remedies under the U.S. federal securities laws. These rulings paved the way\nfor 125+ global institutional investors to pursue their claims and marked the first time, post-Morrison,\nthat U.S. and foreign investors, pursuing foreign claims seeking recovery for losses in a foreign\ncompany\u2019s foreign-traded securities, did so in a U.S. court. In 2017, Pomerantz earned an important\nvictory that expanded investor rights under English law, permitting certain BP investors to pursue a\n\u201cholder claim\u201d theory seeking to recover losses in securities held, rather than purchased anew, in\nreliance on the alleged fraud\u2014a theory barred under the U.S. federal securities laws since Blue Chip\nStamps v. Manor Drug Stores, 421 U.S. 723 (1975). This win was significant, given the dearth of\nprecedent from anywhere recognizing the viability of a \u201cholder claim\u201d under any non-U.S. law and\nholding that a given plaintiff alleged facts sufficiently evidencing reliance and documenting the resulting\nretention of an identifiable amount of shares on a date certain.\n\nIn Q1 2021, Pomerantz secured confidential, favorable monetary settlements from BP for our nearly\nthree dozen clients, including public and private pension funds, money management firms, partnerships,\nand investment trusts from the U.S., Canada, the U.K., France, the Netherlands, and Australia.\n\nIn re Comverse Technology, Inc. Sec. Litig., No. 06-CV-1825 (E.D.N.Y.)\nIn June 2010, Judge Nicholas G. Garaufis of the U.S. District Court for the Eastern District of New York\ngranted final approval of a $225 million settlement proposed by Pomerantz and Lead Plaintiff the\nMenora Group, with Comverse Technology and certain of Comverse\u2019s former officers and directors,\nafter four years of highly contested litigation. The Comverse settlement is one of the largest securities\nclass action settlements reached since the passage of the Private Securities Litigation Reform Act\n(\u201cPSLRA\u201d).1 It is the second-largest recovery in a securities litigation involving the backdating of options,\nas well as one of the largest recoveries\u2014$60 million\u2014from an individual officer-defendant, Comverse\u2019s\nfounder and former CEO, Kobi Alexander.\n\n Other Significant Settlements\n\nEven before the enactment of the PSLRA, Pomerantz represented state agencies in securities class\nactions, including the Treasurer of the Commonwealth of Pennsylvania (recovered $100 million) against\na major investment bank. In re Salomon Brothers Treasury Litig., No. 91-cv-5471 (S.D.N.Y.).\n\n\n1 Institutional Shareholder Services, SCAS Top 100 Settlements Quarterly Report (Sept. 30, 2010).\n\n\n\nwww.pomlaw.com 5\n\n\n J.R.000033\n\f Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 7 of 9\n\n\n\nPomerantz recovered $50 million for the Treasurer of the State of New Jersey and several New Jersey\npension funds in an individual action. This was a substantially higher recovery than what our clients\nwould have obtained had they remained in a related federal class action. Treasurer of State of New\nJersey v. AOL Time Warner, Inc. (N.J. Super. Ct. Law Div., Mercer Cty.).\n\nPomerantz has litigated numerous cases for the Louisiana School Employees\u2019 Retirement System. For\nexample, as Lead Counsel, Pomerantz recovered $74.75 million in a securities fraud class action against\nCitigroup, its CEO Sanford Weill, and its now infamous telecommunications analyst Jack Grubman. In re\nSalomon Analyst AT&T Litig., No. 02-cv-6801 (S.D.N.Y.) Also, the Firm played a major role in a complex\nantitrust and securities class action which settled for over $1 billion. In re NASDAQ Market-Makers\nAntitrust Litig., MDL No. 1023 (S.D.N.Y.). Pomerantz was a member of the Executive Committee in In re\nTranskaryotic Therapies, Inc. Securities Litigation, C.A. No. 03-10165 (D. Mass.), helping to win a $50\nmillion settlement for the class.\n\nIn 2008, together with Co-Counsel, Pomerantz identified a substantial opportunity for recovery of losses\nin Countrywide mortgage-backed securities (\"MBS\") for three large New Mexico funds (New Mexico\nState Investment Council, New Mexico Public Employees' Retirement Association, and New Mexico\nEducational Retirement Board), which had been overlooked by all of the firms then in their securities\nlitigation pool. We then filed the first non-class lawsuit by a public institution with respect to\nCountrywide MBS. See N.M. State Inv. Council v. Countrywide Fin. Corp., No. D-0101-CV-2008-02289\n(N.M. 1st Dist. Ct.). In Fall 2010, we negotiated for our clients an extremely favorable but confidential\nsettlement.\n\nOver its long history, Pomerantz has achieved significant settlements in numerous cases, a sampling of\nwhich appears below:\n\n\u2022 In re Petrobras Sec. Litig., No. 14-cv-9662 (S.D.N.Y. 2018)\n $3 billion settlement of securities class action in which Pomerantz was Lead Counsel.\n\u2022 Pirnik v. Fiat Chrysler Automobiles N.V. et al., No. 1:15-cv-07199-JMF (S.D.N.Y)\n $110 million settlement of securities class action in which Pomerantz was Lead Counsel\n\u2022 In re Yahoo!, Inc. Sec. Litig., No. 17-cv-00373 (N.D. Cal. 2018)\n $80 million settlement of securities class action in which Pomerantz was Co-Lead Counsel\n\u2022 In re Libor Based Financial Instruments Antitrust Litig., 1:11-md-2262\n $31 million partial settlement with three defendants in this multi-district litigation in which\n Pomerantz represents the Berkshire Bank and the Government Development Bank for Puerto Rico\n\u2022 Kaplan v. S.A.C. Capital Advisors, L.P., No. 12-cv-9350 (S.D.N.Y. 2017)\n $135 million settlement of class action in which Pomerantz was Co-Lead Counsel.\n\u2022 In re Groupon, Inc. Sec. Litig., No. 12-cv-02450 (N.D. Ill. 2015)\n $45 million settlement of class action in which Pomerantz was sole Lead Counsel.\n\u2022 In re Elan Corp. Sec. Litig., No. 05-cv-2860 (S.D.N.Y. 2005)\n $75 million settlement in class action arising out of alleged accounting manipulations.\n\u2022 In re Safety-Kleen Corp. Stockholders Litig., No. 00-cv-736-17 (D.S.C. 2004)\n $54.5 million in total settlements in class action alleging accounting manipulations by corporate\n officials and auditors; last settlement reached on eve of trial.\n\u2022 Duckworth v. Country Life Ins. Co., No. 1998-CH-01046 (Ill. Cir. Ct., Cook Cty. 2000)\n $45 million recovery.\n\n\nwww.pomlaw.com 6\n\n\n J.R.000034\n\f Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 8 of 9\n\n\n\n\u2022 Snyder v. Nationwide Ins. Co., No. 97/0633 (N.Y. Sup. Ct. Onondaga Cty. 1998)\n Settlement valued at $100 million in derivative case arising from injuries to consumers purchasing\n life insurance policies.\n\u2022 In re National Health Lab., Inc. Sec. Litig., No. CV 92-1949 (S.D. Cal. 1995)\n $64 million recovery.\n\u2022 In re First Executive Corp. Sec. Litig., No. 89-cv-07135 (C.D. Cal. 1994)\n $102 million recovery for the class, exposing a massive securities fraud arising out of the Michael\n Milken debacle.\n\u2022 In re Boardwalk Marketplace Sec. Litig., MDL No. 712 (D. Conn. 1994)\n Over $66 million benefit in securities fraud action.\n\u2022 In re Telerate, Inc. S\u2019holders Litig., C.A. No. 1115 (Del. Ch. 1989)\n $95 million benefit in case alleging violation of fiduciary duty under state law.\n\nPomerantz has also obtained stellar results for private institutions and Taft-Hartley funds. Below are a\nfew examples:\n\n\u2022 In re Charter Commc\u2019ns, Inc. Sec. Litig., No. 02-cv-1186 (E.D. Mo. 2005) (sole Lead Counsel for Lead\n Plaintiff StoneRidge Investment Partners LLC); $146.25 million class settlement, where Charter also\n agreed to enact substantive improvements in corporate governance.\n\u2022 In re Am. Italian Pasta Sec. Litig., No. 05-cv-865 (W.D. Mo. 2008) (sole Lead Counsel for Lead Plaintiff\n Ironworkers Locals 40, 361 and 417; $28.5 million aggregate settlements).\n\u2022 Richardson v. Gray, No. 116880/1995 (N.Y. Sup. Ct. N.Y. Cty. 1999); and In re Summit Metals, No. 98-\n 2870 (Bankr. D. Del. 2004) (two derivative actions where the Firm represented C.C. Partners Ltd. and\n obtained judgment of contempt against controlling shareholder for having made \u201cextraordinary\u201d\n payments to himself in violation of a preliminary injunction; persuaded the court to jail him for two\n years upon his refusal to pay; and, in a related action, won a $43 million judgment after trial and\n obtained turnover of stock of two companies).\n\n Shaping the Law\n\nNot only has Pomerantz established a long track record of obtaining substantial monetary recoveries for\nour clients; whenever appropriate, we also pursue corporate governance reforms on their behalf. In In\nre Chesapeake Shareholders Derivative Litigation, No. CJ-2009-3983 (Okla. Dist. Ct., Okla. Cty. 2011), for\nexample, the Firm served as Co-Lead Counsel, representing a public pension client in a derivative case\narising from an excessive compensation package granted to Chesapeake\u2019s CEO and founder. This was a\nderivative action, not a class action. Yet it is illustrative of the results that can be obtained by an\ninstitutional investor in the corporate governance arena. There we obtained a settlement which called\nfor the repayment of $12.1 million and other consideration by the CEO. The Wall Street Journal (Nov. 3,\n2011) characterized the settlement as \u201ca rare concession for the 52-year-old executive, who has run the\ncompany largely by his own rules since he co-founded it in 1989.\u201d The settlement also included\ncomprehensive corporate governance reforms.\n\nThe Firm has won many landmark decisions that have enhanced shareholders\u2019 rights and improved\ncorporate governance. These include decisions that established that:\n\n\n\n\nwww.pomlaw.com 7\n\n\n J.R.000035\n\f Case 8:25-cv-02581-TDC Document 14-8 Filed 10/06/25 Page 9 of 9\n\n\n\n\u2022 defendants seeking to rebut the Basic presumption of reliance on an efficient market must do so by\n a preponderance of the evidence. Waggoner v. Barclays PLC, 875 F.3d 79 (2d Cir. 2017) (Strougo v.\n Barclays PLC, in the court below);\n\u2022 plaintiffs have no burden to show price impact at the class certification stage. Waggoner v. Barclays\n PLC, 875 F.3d 79 (2d Cir. 2017) (Strougo v. Barclays PLC, in the court below);\n\u2022 the ascertainability doctrine requires only that a class be defined using objective criteria that\n establish a membership with definite boundaries. Universities Superannuation Scheme Ltd. v.\n Petr\u00f3leo Brasileiro S.A. Petrobras, 862 F.3d 250 (2d Cir. 2017);\n\u2022 companies cannot adopt bylaws to regulate the rights of former stockholders. Strougo v. Hollander,\n C.A. No. 9770-CB (Del. Ch. 2015);\n\u2022 a temporary rise in share price above its purchase price in the aftermath of a corrective disclosure\n does not eviscerate an investor\u2019s claim for damages. Acticon AG v. China Ne. Petroleum Holdings\n Ltd., 692 F.3d 34 (2d Cir. 2012);\n\u2022 an MBS holder may bring claims if the MBS price declines even if all payments of principal and\n interest have been made. Transcript of Proceedings, N.M. State Inv. Council v. Countrywide Fin.\n Corp., No. D-0101-CV-2008-02289 (N.M. 1st Dist. Ct. Mar. 25, 2009);\n\u2022 when a court selects a Lead Plaintiff under the Private Securities Litigation Reform Act (\u201cPSLRA\u201d), the\n standard for calculating the \u201clargest financial interest\u201d must take into account sales as well as\n purchases. In re Comverse Tech., Inc. Sec. Litig., No. 06-cv-1825, 2007 U.S. Dist. LEXIS 14878 (E.D.N.Y.\n Mar. 2, 2007);\n\u2022 a managing underwriter can owe fiduciary duties of loyalty and care to an issuer in connection with\n a public offering of the issuer stock, even in the absence of any contractual agreement. Professor\n John C. Coffee, a renowned Columbia University securities law professor, commenting on the ruling,\n stated: \u201cIt\u2019s going to change the practice of all underwriting.\u201d EBC I, Inc. v. Goldman Sachs & Co., 5\n N.Y. 3d 11 (2005);\n\u2022 purchasers of options have standing to sue under federal securities laws. In re Green Tree Fin. Corp.\n Options Litig., No. 97-2679, 2002 U.S. Dist. LEXIS 13986 (D. Minn. July 29, 2002);\n\u2022 shareholders have a right to a jury trial in derivative actions. Ross v. Bernhard, 396 U.S. 531 (1970);\n\u2022 a company may have the obligation to disclose to shareholders its Board\u2019s consideration of\n important corporate transactions, such as the possibility of a spin-off, even before any final decision\n has been made. Kronfeld v. Trans World Airlines, Inc., 832 F.2d 726 (2d Cir. 1987);\n\u2022 specific standards for assessing whether mutual fund advisors breach fiduciary duties by charging\n excessive fees. Gartenberg v. Merrill Lynch Asset Mgmt., Inc., 740 F.2d 190 (2d Cir. 1984);\n\u2022 investment advisors to mutual funds are fiduciaries who cannot sell their trustee positions for a\n profit. Rosenfeld v. Black, 445 F.2d 1337 (2d Cir. 1971); and\n\u2022 management directors of mutual funds have a duty to make full disclosure to outside directors \u201cin\n every area where there was even a possible conflict of interest.\u201d Moses v. Burgin, 445 F.2d 369 (1st\n Cir. 1971).\n\n\n\n\nwww.pomlaw.com 8\n\n\n J.R.000036\n\f","ocr_status":1,"date_upload":"2026-05-18T06:04:32.682285-07:00","document_number":"14","attachment_number":8,"pacer_doc_id":"093015216145","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 5 - Pomerantz Firm Resume","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528452/","id":479528452,"tags":[],"absolute_url":"/docket/71033169/14/9/collier-v-altimmune-inc/","date_created":"2026-05-18T06:03:42.036741-07:00","date_modified":"2026-05-22T03:43:29.835501-07:00","sha1":"ec5c1a2d752ef7646e78ac5ddfdd3cb605c72285","page_count":4,"file_size":162305,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.9.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.14.9.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 14-9 Filed 10/06/25 Page 1 of 4\n\n\n\n UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF MARYLAND\n (Southern Division)\n\n\nDAVE COLLIER, Individually and on Behalf Case No. 8:25-cv-02581-TDC\nof All Others Similarly Situated,\n\n Plaintiff,\n\n v.\n\nALTIMMUNE, INC. et al.,\n\n Defendants.\n\n\n\n[PROPOSED] ORDER APPOINTING CO-LEAD PLAINTIFFS AND APPROVING\n SELECTION OF COUNSEL\n\f Case 8:25-cv-02581-TDC Document 14-9 Filed 10/06/25 Page 2 of 4\n\n\n\n WHEREAS, the Court has considered the competing motions for appointment as lead\n\nplaintiff and approval of selection of counsel,\n\n IT IS HEREBY ORDERED THAT:\n 1. Having reviewed all pending motions and accompanying memoranda of law, the\n\nCourt hereby appoints Yiming Cao (\u201cCao\u201d), Yaping Wu (\u201cWu\u201d and, together with Cao, the \u201cCao-\n\nWu Family\u201d), and Thomas Rainwater (\u201cRainwater\u201d) as Co-Lead Plaintiffs in the above-captioned\n\naction (the \u201cAction\u201d). The Cao-Wu Family and Rainwater satisfy the requirements for\n\nappointment as Co-Lead Plaintiffs pursuant to Section 21D(a)(3)(B)(iii) of the Private Securities\n\nLitigation Reform Act of 1995 (the \u201cPSLRA\u201d).\n\n 2. Co-Lead Plaintiffs, pursuant to Section 21D(a)(3)(B)(v) of the PSLRA, have\n\nselected and retained Pomerantz LLP as Lead Counsel and Cohen Milstein Sellers & Toll PLLC\n\nas Liaison Counsel to represent the Class in the Action.\n\n 3. Lead Counsel shall have the following responsibilities and duties, to be carried out\n\neither personally or through counsel whom Lead Counsel shall designate:\n\n (a) to coordinate the briefing and argument of motions;\n\n (b) to coordinate the conduct of discovery proceedings;\n\n (c) to coordinate the examination of witnesses in depositions;\n\n (d) to coordinate the selection of counsel to act as a spokesperson at pretrial\n conferences;\n\n (e) to call meetings of the plaintiffs\u2019 counsel as they deem necessary and\n appropriate from time to time;\n\n (f) to coordinate all settlement negotiations with counsel for defendants;\n\n (g) to coordinate and direct the pretrial discovery proceedings and the\n preparation for trial and the trial of this matter and to delegate work\n responsibilities to selected counsel as may be required; and\n\n (h) to supervise any other matters concerning the prosecution, resolution, or\n settlement of the Action.\n\f Case 8:25-cv-02581-TDC Document 14-9 Filed 10/06/25 Page 3 of 4\n\n\n\n 4. No motion, request for discovery, or other pretrial proceedings shall be initiated or\n\nfiled by any plaintiffs without the approval of Lead Counsel, so as to prevent duplicative pleadings\n\nor discovery by plaintiffs. No settlement negotiations shall be conducted without the approval of\n\nLead Counsel.\n\n 5. Every pleading in this Action, and any related action that is consolidated with this\n\nAction, shall hereafter bear the following caption:\n\n UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF MARYLAND\n (Southern Division)\n\n IN RE ALTIMMUNE, INC. SECURITIES Case No. 8:25-cv-02581-TDC\n LITIGATION\n CLASS ACTION\n THIS DOCUMENT RELATES TO:\n [TITLE OF DOCUMENT]\n\n\n 6. When the document being filed pertains to all actions, the phrase \u201cAll Actions\u201d\n\nshall appear immediately after the phrase \u201cThis Document Relates To:\u201d. When the document\n\napplies to some, but not all, of the actions, the document shall list, immediately after the phrase\n\n\u201cThis Document Relates To:\u201d, the docket number for each individual action to which the document\n\napplies, along with the name of the first-listed plaintiff in said action.\n\n 7. Counsel in any related action that is consolidated with this Action shall be bound\n\nby the organization of plaintiffs\u2019 counsel as set forth herein.\n\n 8. Lead Counsel shall have the responsibility of receiving and disseminating Court\n\norders and notices.\n\n 9. Lead Counsel shall be the contact between plaintiffs\u2019 counsel and defendants\u2019\n\ncounsel, and shall direct and coordinate the activities of plaintiffs\u2019 counsel.\n\n 10. During the pendency of this litigation, or until further order of this Court, the parties\n\n\n\n 2\n\f Case 8:25-cv-02581-TDC Document 14-9 Filed 10/06/25 Page 4 of 4\n\n\n\nshall take reasonable steps to preserve all documents within their possession, custody, or control,\n\nincluding computer-generated and stored information, and materials such as computerized data\n\nand electronic mail, containing information which is relevant, or which may lead to the discovery\n\nof information relevant, to the subject matter of the pending litigation.\n\n SO ORDERED.\n\nDated: ___________________, 2025\n Greenbelt, Maryland\n\n HONORABLE THEODORE D. CHUANG\n UNITED STATES DISTRICT JUDGE\n DISTRICT OF MARYLAND\n\n\n\n\n 3\n\f","ocr_status":2,"date_upload":"2026-05-18T06:04:35.939860-07:00","document_number":"14","attachment_number":9,"pacer_doc_id":"093015216146","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Text of Proposed Order","acms_document_guid":""}],"date_created":"2025-12-01T00:06:50.195236-08:00","date_modified":"2026-07-12T22:47:08.687797-07:00","date_filed":"2025-10-06","time_filed":null,"entry_number":14,"recap_sequence_number":"2025-10-06.006","pacer_sequence_number":47,"description":"MOTION to Appoint Counsel and Appointment as Co-Lead Plaintiffs by Yiming Cao, Yaping Wu, Thomas Rainwater (Attachments: # 1 Memorandum in Support, # 2 Declaration of Jeremy A. Lieberman, # 3 Index of Exhibits, # 4 Exhibit 1 - Damages Analysis, # 5 Exhibit 2 - PSLRA Notice, # 6 Exhibit 3 - Shareholder Certifications, # 7 Exhibit 4 - Joint Declaration, # 8 Exhibit 5 - Pomerantz Firm Resume, # 9 Text of Proposed Order)(Sommers, Daniel) (Entered: 10/06/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/445672460/","id":445672460,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71033169/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/460378080/","id":460378080,"tags":[],"absolute_url":"/docket/71033169/13/collier-v-altimmune-inc/","date_created":"2025-12-01T00:06:50.139483-08:00","date_modified":"2026-07-12T22:47:08.663889-07:00","sha1":"99ac6fbc155c88b8ee9793ac9f4179b638a66e77","page_count":3,"file_size":145808,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 13 Filed 10/06/25 Page 1 of 3\n\n\n\n UNITED STATES DISTRICT COURT\n DISTRICT OF MARYLAND\n\nDAVE COLLIER, Individually and on Behalf\nof All Others Similarly Situated,\n\n Plaintiff,\n Case No.: 8:25-cv-02581-TDC\nv.\n Hon. Theodore D. Chuang\nALTIMMUNE, INC., VIPIN K. GARG, and\nMATTHEW SCOTT HARRIS,\n\n Defendants.\n\n\n NOTICE OF MOTION OF CARLOS RIOS FOR APPOINTMENT AS LEAD\n PLAINTIFF AND APPROVAL OF SELECTION OF COUNSEL\n\n TO THE CLERK OF THE COURT, ALL PARTIES AND THEIR RESPECTIVE\n\nATTORNEYS OF RECORD:\n\n PLEASE TAKE NOTICE that on a date and time as may be set by the Court, at the United\n\nStates District Court for the District of Maryland, Movant Carlos Rios (\u201cMovant\u201d) will respectfully\n\nmove this Court, pursuant to Section 21D(a)(3)(B) of the Securities Exchange Act of 1934 (the\n\n\u201cExchange Act\u201d), 15 U.S.C. \u00a778u-4(a)(3)(B), as amended by the Private Securities Litigation\n\nReform Act of 1995 (the \u201cPSLRA\u201d), for entry of an Order: (1) appointing Movant as Lead Plaintiff\n\non behalf of all investors who purchased or otherwise acquired Altimmune, Inc. (\u201cAltimmune\u201d or\n\nthe \u201cCompany\u201d) securities between August 10, 2023 and June 25, 2025, inclusive; (2) approving\n\nMovant\u2019s selection of the law firm of Levi & Korsinsky, LLP (\u201cLevi & Korsinsky\u201d) as Lead\n\nCounsel for the putative class; and (3) granting such other and further relief as the Court may deem\n\njust and proper.\n\f Case 8:25-cv-02581-TDC Document 13 Filed 10/06/25 Page 2 of 3\n\n\n\n This motion is based on the accompanying Memorandum of Law in support thereof, the\n\nDeclaration of Jordan A. Cafritz filed herewith and all exhibits thereto, the pleadings and other\n\nfilings herein, and such other written and oral arguments as may be permitted by the Court.\n\n WHEREFORE, Movant respectfully requests that the Court: (1) appoint Movant as Lead\n\nPlaintiff on behalf of all similarly situated Altimmune investors; (2) approve Movant\u2019s selection\n\nof Levi & Korsinsky as Lead Counsel for the putative class; and (3) grant such other and further\n\nrelief as the Court may deem just and proper.\n\n\nDated: October 6, 2025 Respectfully Submitted,\n\n\n LEVI & KORSINSKY, LLP\n\n\n By: /s/ Jordan A. Cafritz\n Jordan A. Cafritz (Bar #:20908)\n 1101 Vermont Ave., NW Suite 800\n Washington, D.C. 20005\n Tel: (202) 524-4290\n Fax: (202) 333-2121\n Email: jcafritz@zlk.com\n\n LEVI & KORSINSKY, LLP\n Adam M. Apton (pro hac vice forthcoming)\n 33 Whitehall Street, 27th Floor\n New York, NY 10004\n Tel: (212) 363-7500\n Fax: (212) 363-7171\n Email: aapton@zlk.com\n\n Lead Counsel for Carlos Rios and\n [Proposed] Lead Counsel for the Class\n\n\n\n\n 2\n\f Case 8:25-cv-02581-TDC Document 13 Filed 10/06/25 Page 3 of 3\n\n\n\n CERTIFICATE OF SERVICE\n\n I, Jordan A. Cafritz, hereby certify that this document was filed through the CM/ECF\n\nsystem and will be sent electronically to the registered participants as identified on the Notice of\n\nElectronic Filing (NEF) on this 6th day of October 2025.\n\n /s/ Jordan A. Cafritz\n Jordan A. Cafritz\n\n\n\n\n 3\n\f","ocr_status":2,"date_upload":"2026-05-18T06:04:30.348407-07:00","document_number":"13","attachment_number":null,"pacer_doc_id":"093015216077","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528531/","id":479528531,"tags":[],"absolute_url":"/docket/71033169/13/1/collier-v-altimmune-inc/","date_created":"2026-05-18T06:04:32.852716-07:00","date_modified":"2026-05-22T03:44:25.514889-07:00","sha1":"93d5810ecf14a21a5cae7f52872f7145350f33bf","page_count":13,"file_size":214647,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 1 of 13\n\n\n\n UNITED STATES DISTRICT COURT\n DISTRICT OF MARYLAND\n\nDAVE COLLIER, Individually and on Behalf\nof All Others Similarly Situated,\n\n Plaintiff,\n Case No.: 8:25-cv-02581-TDC\nv.\n Hon. Theodore D. Chuang\nALTIMMUNE, INC., VIPIN K. GARG, and\nMATTHEW SCOTT HARRIS,\n\n Defendants.\n\n\n MEMORANDUM OF LAW IN SUPPORT OF THE MOTION OF CARLOS RIOS\n FOR APPOINTMENT AS LEAD PLAINTIFF AND\n APPROVAL OF SELECTION OF COUNSEL\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 2 of 13\n\n\n\n Movant Carlos Rios (\u201cMovant\u201d), on behalf of himself and all similarly situated persons,\n\nrespectfully submits this Memorandum of Law in support of his motion (\u201cMotion\u201d): (1) appointing\n\nMovant as Lead Plaintiff on behalf of all investors who purchased or otherwise acquired\n\nAltimmune, Inc. (\u201cAltimmune\u201d or the \u201cCompany\u201d) securities between August 10, 2023 and June\n\n25, 2025, inclusive (the \u201cClass\u201d, who purchased during the \u201cClass Period\u201d); (2) approving\n\nMovant\u2019s selection of the law firm of Levi & Korsinsky, LLP (\u201cLevi & Korsinsky\u201d) as Lead\n\nCounsel for the putative class; and (3) granting such other and further relief as the Court may deem\n\njust and proper.\n\n PRELIMINARY STATEMENT\n\n Presently pending before the Court is the above-captioned securities class action (the\n\n\u201cAction\u201d) brought on behalf of all investors who purchased or otherwise acquired Altimmune\n\nsecurities during the Class Period. Plaintiff in the Action alleges violations of \u00a7\u00a7 10(b) and 20(a)\n\nof the Securities Exchange Act of 1934 (\u201cExchange Act\u201d) (15 U.S.C. \u00a7\u00a7 78j(b) and 78t(a)) and\n\nRule 10b-5 promulgated thereunder by the SEC (17 C.F.R. \u00a7240.10b-5), against the Company,\n\nVipin K. Garg (\u201cGarg\u201d), and Matthew Scott Harris (\u201cHarris\u201d) (collectively, the \u201cDefendants\u201d and\n\nwithout the Company, the \u201cIndividual Defendants\u201d).\n\n The Private Securities Litigation Reform Act of 1995, as amended, 15 U.S.C. \u00a778u-\n\n4(a)(3)(B) (the \u201cPSLRA\u201d), provides for the Court to appoint as lead plaintiff the movant that has\n\nthe largest financial interest in the litigation and has made a prima facie showing that he, she, or it\n\nis an adequate class representative under Rule 23 of the Federal Rules of Civil Procedure. 15\n\nU.S.C. \u00a778u4(a)(3)(B)(iii)(I)(aa)-(cc); see also Tchatchou v. India Globalization Capital, Inc., No.\n\n8:18-cv03396-PWG, 2019 WL 1004591, at *3 (D. Md. Feb. 28, 2019). Movant has lost\n\n\n\n\n 2\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 3 of 13\n\n\n\napproximately $79,449.72 as a result of the alleged fraud during the Class Period. 1 Movant\n\nbelieves that he has the largest financial interest in the outcome of this case. Moreover, Movant\n\nsatisfies the requirements of Rule 23 in that his claims are typical of the claims of the Class, and\n\nhe will fairly and adequately represent the interests of the Class.\n\n For the reasons summarized herein and discussed more fully below, Movant\u2019s Motion\n\nshould be approved in its entirety.\n\n FACTUAL BACKGROUND 2\n\n Altimmune is a clinical stage biopharmaceutical company focused on developing\n\ntreatments for obesity, metabolic and liver diseases. \u00b6 19. The Company\u2019s lead product candidate,\n\npemvidutide (formerly known as ALT-801), is a novel, investigational, peptide-based GLP-\n\n1/glucagon dual receptor agonist. Id. Pemvidutide is currently in clinical development for obesity\n\nand metabolic associated steatohepatitis (\u201cMASH\u201d). Id.\n\n The statements in Paragraphs 20 to 30 of the Collier Complaint were false and/or materially\n\nmisleading. \u00b6 31. Defendants created the false impression that they possessed reliable information\n\npertaining to the results of the Company\u2019s IMPACT Phase 2b MASH trial. Id. In truth, Altimmune\n\nfailed to meet an important statistical significance marker relating to the fibrosis reduction primary\n\nendpoint. Id. The Company had consistently touted its inflated expectations for positive topline\n\nresults from the IMPACT Phase 2b MASH trial, while concealing higher responses in the placebo\n\n\n\n\n1\n Certification identifying Movant\u2019s transactions in Altimmune, as required by the PSLRA, as well\nas a chart identifying his losses, are attached to the Declaration of Jordan A. Cafritz, dated October\n6, 2025 (\u201cCafritz Decl.\u201d), as Exhibits A and B, respectively.\n2\n Citations to \u201c\u00b6 __\u201d are to paragraphs of the Class Action Complaint (the \u201cCollier Complaint\u201d)\nfiled in the action styled Collier v. Altimmune, Inc., et al., No. 8:25-cv-02581-TDC (the \u201cCollier\nAction\u201d). Unless otherwise defined, capitalized terms shall have the same meaning set forth in the\nCollier Complaint. The facts set forth in the Collier Complaint are incorporated herein by\nreference.\n\n\n 3\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 4 of 13\n\n\n\ngroup, which they knew or should have known would negative impact the topline results. Id.\n\nAltimmune\u2019s IMPACT Phase 2b MASH trial results fell short of reality, as shown by the\n\nCompany\u2019s topline data, which show that the statistical significance was not achieved for the\n\nfibrosis reduction primary endpoint. Id.\n\n On June 26, 2025, Altimmune published a press release announcing topline results from\n\nthe IMPACT Phase 2b Trial of Pemvidutide in the Treatment of MASH. \u00b6 32.\n\n Later the same day, Altimmune hosted a Special Call detailing the topline results from the\n\nIMPACT Phase 2b Trial of Pemvidutide in the Treatment of MASH. Defendant Harris provided\n\nthe following analysis pertaining to the results. \u00b6 33.\n\n During a question-and-answer segment of the Special Call, analysts probed Defendants\n\nregarding the IMPACT Phase 2b MASH trial results. \u00b6 34.\n\n The aforementioned press releases and statements made by the Individual Defendants are\n\nin direct contrast to statements they made during the above-referenced press releases. \u00b6 35. On\n\nthose calls, Defendants repeatedly touted the Company\u2019s positive expectations for topline results\n\nfrom its IMPACT Phase 2b MASH trial. Id. In truth, Altimmune failed to account for high placebo\n\nresponses during the study leading the critical miss of the fibrosis reduction primary endpoint. Id.\n\nFurthermore, when directly asked about this failure to reach statistical significance, Defendants\u2019\n\nresponse was less than reassuring; particularly, that Altimmune was hoping to reach the statistical\n\nsignificance target during the Phase 3 trial. Id.\n\n Investors and analysts reacted immediately to Altimmune\u2019s revelation. \u00b6 36. The price of\n\nAltimmune\u2019s common stock declined dramatically. Id. From a closing market price of $7.71 per\n\nshare on June 25, 2025, Altimmune\u2019s stock price fell to $3.61 per share on June 26, 2025, a decline\n\nof 53.2% in the span of just a single day. Id.\n\n\n\n\n 4\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 5 of 13\n\n\n\n ARGUMENT\n\n I. APPOINTING MOVANT AS LEAD PLAINTIFF IS APPROPRIATE\n\n A. The PSLRA\u2019s Provisions Concerning the Appointment of Lead Plaintiff\n\n The PSLRA mandates that the Court decide the lead plaintiff issue \u201c[a]s soon as\n\npracticable.\u201d 15 U.S.C. \u00a778u-4(a)(3)(B)(ii). The PSLRA establishes the procedure for appointment\n\nof the lead plaintiff in \u201ceach private action arising under [the Exchange Act] that is brought as a\n\nplaintiff class action pursuant to the Federal Rules of Civil Procedure.\u201d 15 U.S.C. \u00a778u-4(a) and\n\n(a)(3)(B).\n\n The PSLRA provides that within 20 days after the date on which the first class action is\n\nfiled, the plaintiff to that action shall cause to be published in a widely circulated national business\n\npublication or wire service, a notice advising members of the proposed class of the pendency of\n\nthe action and their right to move for appointment as lead plaintiff within 60 days of the notice\n\npublication. 15 U.S.C. \u00a778u-4(a)(3)(A).\n\n Under 15 U.S.C. \u00a778u-4(a)(3)(B)(i), the Court will, no later than 90 days after the date on\n\nwhich a notice is published, consider any motion filed by a purported class member in response to\n\nthe notice and appoint as lead plaintiff the plaintiff that the court determines to be \u201cmost capable\n\nof adequately representing the interests of class members.\u201d The PSLRA provides a presumption\n\nthat the most \u201cadequate plaintiff\u201d to serve as lead plaintiff is the \u201cperson or group of persons\u201d that:\n\n (aa) has either filed the complaint or made a motion in response to a notice;\n\n (bb) in the determination of the court, has the largest financial interest in the relief sought\n\n by the class; and\n\n (cc) otherwise satisfies the requirements of Rule 23 of the Federal Rules of Civil\n\n Procedure.\n\n\n\n\n 5\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 6 of 13\n\n\n\n15 U.S.C. \u00a778u-4(a)(3)(B)(iii)(I). The presumption may be rebutted only upon proof by a Class\n\nmember that the presumptive most adequate plaintiff \u201cwill not fairly and adequately protect the\n\ninterests of the class\u201d or \u201cis subject to unique defenses that render such plaintiff incapable of\n\nadequately representing the class.\u201d 15 U.S.C. \u00a778u-4(a)(3)(B)(iii)(II).\n\n As set forth below, Movant has complied with the procedural prerequisites of the PSLRA\n\nand sustained, to the best of his knowledge, the largest financial interest in the litigation of any\n\nother Class member(s) seeking appointment as lead plaintiff. Movant is also unaware of any unique\n\ndefenses that Defendants could raise against him. Therefore, Movant is entitled to the presumption\n\nthat he is the most adequate plaintiff to represent the Class and, as a result, should be appointed\n\nlead plaintiff in the action.\n\n B. Movant Satisfies the Lead Plaintiff Provisions of the PSLRA\n\n As described in further detail below, Movant should be appointed lead plaintiff because he\n\nsatisfies all of the requirements of the PSLRA. Movant filed a timely motion to be appointed lead\n\nplaintiff, holds the largest financial interest in the relief sought by the Class, and satisfies the\n\ntypicality and adequacy requirements of Rule 23.\n\n 1. Movant Filed a Timely Motion\n\n On August 5, 2025, which was within twenty (20) days of the filing of the first-filed\n\ncomplaint as required by 15 U.S.C. \u00a778u-4(a)(3)(A)(i), Levi & Korsinsky, counsel of behalf of\n\nplaintiff in the Collier Action, published notice of that action over Globe Newswire, a widely\n\ncirculated national business-oriented wire service. See Cafritz Decl., Ex. C. Consequently, any\n\nmember of the proposed Class was required to seek appointment as lead plaintiff within 60 days\n\nafter publication of that notice. See 15 U.S.C. \u00a778u-4(a)(3)(A)(i). Therefore, the time period in\n\nwhich class members may move to be appointed lead plaintiff herein under 15 U.S.C. \u00a778u-\n\n\n\n\n 6\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 7 of 13\n\n\n\n4(a)(3)(A) and (B) expires on October 6, 2025. Pursuant to the PSLRA and within the requisite\n\ntime frame after publication of the required notice, Movant herein timely moves this Court to be\n\nappointed lead plaintiff on behalf of all members of the Class.\n\n 2. Movant Has the Largest Financial Interest in the Relief Sought By the\n Class\n\n According to 15 U.S.C. \u00a778u-4(a)(3)(B)(iii), the Court shall appoint as lead plaintiff the\n\nmovant or movants with the largest financial loss in the relief sought by the action. As\n\ndemonstrated herein, Movant has the largest known financial interest in the relief sought by the\n\nClass. See Cafritz Decl., Ex. B. The movant who has the largest financial interest in this litigation\n\nand meets the adequacy and typicality requirements of Rule 23 is presumptively the lead plaintiff.\n\nSee India Globalization Capital, Inc., 2019 WL 1004591, at *3. Under the PSLRA, damages are\n\ncalculated based on (i) the difference between the purchase price paid for the shares and the\n\naverage trading price of the shares during the 90-day period beginning on the date the information\n\ncorrecting the misstatement was disseminated, or (ii) the difference between the purchase price\n\npaid for the shares and the average trading price of the shares between the date when the\n\nmisstatement was corrected and the date on which the plaintiff sold their shares, if they sold their\n\nshares before the end of the 90-day period. 15 U.S.C. \u00a778u-4(e).\n\n Within the Class Period, Movant purchased Altimmune securities in reliance upon the\n\nmaterially false and misleading statements issued by the Defendants and was injured thereby.\n\nMovant suffered substantial losses of approximately $79,449.72 as a result of the Defendants\u2019\n\nalleged fraudulent statements. See Cafritz Decl., Ex. B. Movant, thus, has a significant financial\n\ninterest in the outcome of this case. To the best of his knowledge, there are no other applicants\n\nwho have sought, or are seeking, appointment as lead plaintiff that have a larger financial interest\n\nand also satisfy Rule 23.\n\n\n 7\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 8 of 13\n\n\n\n 3. Movant Meets Rule 23\u2019s Typicality and Adequacy Requirements\n\n Pursuant to 15 U.S.C. \u00a778u-4(a)(3)(B)(iii), in addition to possessing the largest financial\n\ninterest in the outcome of the litigation, the lead plaintiff must also \u201cotherwise satisfy the\n\nrequirements of Rule 23 of the Federal Rules of Civil Procedure.\u201d 15 U.S.C. \u00a778u-\n\n4(a)(3)(B)(iii)(I)(cc). Rule 23(a) provides that a class may be certified only if the following four\n\nrequirements are satisfied: (1) the class is so numerous that joinder of all members is impracticable;\n\n(2) there are questions of law or fact common to the class; (3) the claims or defenses of the\n\nrepresentative party are typical of the claims or defenses of the class; and (4) the representative\n\nparty will fairly and adequately protect the interests of the class. Of these four prerequisites, only\n\ntwo\u2014typicality and adequacy\u2014directly address the personal characteristics of the lead plaintiff\n\nmovant. Consequently, in deciding a lead plaintiff motion, the Court should limit its inquiry to the\n\ntypicality and adequacy prongs of Rule 23(a) and defer examination of the remaining requirements\n\nuntil a class certification motion is filed. See Klugmann v. Am. Capital Ltd., No. PJM 09-5,\n\n2009 WL 2499521, at *5 (D. Md. Aug. 13, 2009). See also Haung v. Acterna Corp., 220 F.R.D.\n\n255, 259 (D. Md. 2004)\n\n As detailed below, Movant satisfies both the typicality and adequacy requirements of Rule\n\n23, thereby justifying his appointment as lead plaintiff.\n\n (i) Movant\u2019s Claims Are Typical of the Claims of the Class\n\n Under Rule 23(a)(3), the claims or defenses of the representative parties must be typical of\n\nthose of the class. A plaintiff satisfies the typicality requirement if the plaintiff has: (a) suffered\n\nthe same injuries as the absent class members; (b) the injuries are as a result of the same course of\n\n\n\n\n 8\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 9 of 13\n\n\n\nconduct by defendants; and (c) the plaintiff\u2019s claims are based on the same legal issues that prove\n\nthe defendant\u2019s liability. See Id. 3\n\n In this case, the typicality requirement is met because Movant\u2019s claims are identical to, and\n\nneither compete, nor conflict, with the claims of the other Class members. Movant, like the other\n\nmembers of the Class, acquired Altimmune securities during the Class Period at prices artificially\n\ninflated by the Defendants\u2019 materially false and misleading statements and was damaged thereby.\n\nThus, his claims are typical, if not identical, to those of the other members of the Class because\n\nMovant suffered losses similar to those of other Class members and his losses resulted from the\n\nDefendants\u2019 common course of wrongful conduct. Accordingly, Movant satisfies the typicality\n\nrequirement of Rule 23(a)(3). Additionally, Movant is not subject to any unique defenses and there\n\nis no evidence of any conflicts between Movant and the other members of the Class.\n\n Movant therefore satisfies the required prima facie showing of the typicality requirement\n\nof Rule 23 for purposes of this Motion.\n\n (ii) Movant Will Fairly and Adequately Protect the Interests of the Class\n\n Movant is also an adequate representative for the Class. Under Rule 23(a)(4),\n\nrepresentative parties must also \u201cfairly and adequately protect the interests of the class.\u201d Adequate\n\nrepresentation will be found if the representative has: (a) retained able and experienced counsel;\n\nand (b) the representative has no fundamental conflicts of interest with the interests of the class as\n\na whole. See India Globalization, 2019 WL 1004591, at *6 (citing Hassine v. Jeffes, 846 F.2d 169,\n\n179 (3d Cir. 1988) ([Court should consider if Movant] \u201chas the ability and incentive to represent\n\nthe claims of the class vigorously, whether it has obtained adequate counsel, and whether there is\n\n\n\n3\n Further, although not relevant to the present motion, a finding of commonality frequently\nsupports a finding of typicality and vice versa. See Gen. Tel. Co. of the Southwest v. Falcon, 457\nU.S. 147, 158 n.13 (1982) (noting that the typicality and commonality requirements tend to merge).\n\n\n 9\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 10 of 13\n\n\n\na conflict between the movant\u2019s claims and those asserted on behalf of the class.\u201d). The PSLRA\n\ndirects the Court to limit its inquiry regarding the adequacy of the movant to whether the interests\n\nof the movant are clearly aligned with the members of the putative Class and whether there is\n\nevidence of any antagonism between the interests of the movant and other members of the Class.\n\n15 U.S.C. \u00a778u-4(a)(3)(B).\n\n Movant has met both of the requirements under Rule 23(a)(4) to fairly and adequately\n\nprotect the interests of the putative class. Not only is there no evidence of conflict between\n\nMovant\u2019s interests and those of the other members of the putative Class, but Movant has a\n\nsignificant and compelling interest in prosecuting the action based on the large financial losses he\n\nsuffered as a result of the wrongful conduct alleged therein. See In re Milestone Scientific Sec.\n\nLitig., 183 F.R.D. 404, 416 (D.N.J. 1998) (Plaintiff\u2019s \u201cfinancial stake in the litigation provides an\n\nadequate incentive for [Plaintiff] to vigorously prosecute the action.\u201d). Indeed Movant has already\n\ntaken significant steps demonstrating that he recognizes and will protect the interests of the Class,\n\nincluding: (1) executing a certification detailing his Class Period transactions and expressing his\n\nwillingness to serve as Class representative; (2) moving this Court to be appointed lead plaintiff;\n\nand (3) retaining competent and experienced counsel, who, as shown below, are experienced in\n\nclass action litigation such as this involving allegations of securities fraud. Therefore, Movant will\n\nprosecute the action vigorously on behalf of the Class.\n\n Moreover, Movant considers himself to be a sophisticated investor, having been investing\n\nin the stock market for 25 years. He resides in Ottawa, Canada, and possesses a master\u2019s degree.\n\nMovant is currently employed as senior director of customer applications engineering at Synopsys,\n\nInc. See Cafritz Decl., Ex. D, Movant\u2019s Declaration in support of his motion.\n\n\n\n\n 10\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 11 of 13\n\n\n\n Accordingly, at this stage of the proceedings, Movant has made the preliminary showing\n\nnecessary to satisfy the typicality and adequacy requirements of Rule 23 and, therefore, satisfies\n\n15 U.S.C. \u00a778u-4(a)(3)(B)(iii)(I)(cc). In addition, because Movant has sustained the largest\n\namount of losses from Defendants\u2019 alleged wrongdoing, he is the presumptive lead plaintiff in\n\naccordance with \u00a778u-4(a)(3)(B)(iii)(I) and should be appointed as such to lead this action.\n\n II. APPOINTING MOVANT\u2019S CHOICE OF COUNSEL IS APPROPRIATE\n\n Pursuant to 15 U.S.C. \u00a778u-4(a)(3)(B)(v), the PSLRA vests authority in the lead plaintiff\n\nto select and retain lead counsel, subject to the Court\u2019s approval. 15 U.S.C. \u00a778u-4(a)(3)(B)(v).\n\nThe Court should interfere with the lead plaintiff\u2019s selection only when necessary to \u201cprotect the\n\ninterests of the class.\u201d 15 U.S.C. \u00a778u-4(a)(3)(B)(iii)(II)(aa). Here, Movant has selected and\n\nretained Levi & Korsinsky as the proposed Lead Counsel for the Class.\n\n As set forth in the accompanying firm r\u00e9sum\u00e9 (Cafritz Decl., Ex. E), Levi & Korsinsky is\n\na highly accomplished firm and currently acting as lead counsel in a number of federal securities\n\nactions and has achieved many multi-million-dollar recoveries for investors. The members of Levi\n\n& Korsinsky have extensive experience in successfully prosecuting complex securities class\n\nactions such as these and are well-qualified to represent the Class. Thus, this Court may be assured\n\nthat in the event that the instant Motion is granted, the members of the Class will receive the highest\n\ncaliber of legal representation.\n\n CONCLUSION\n\n For all the foregoing reasons, Movant respectfully requests that the Court: (1) appoint\n\nMovant as Lead Plaintiff on behalf the Class; (2) approve Movant\u2019s selection of counsel, Levi &\n\nKorsinsky, as Lead Counsel; and (3) grant such other and further relief as the Court may deem just\n\nand proper.\n\n\n\n\n 11\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 12 of 13\n\n\n\nDated: October 6, 2025 Respectfully Submitted,\n\n\n LEVI & KORSINSKY, LLP\n\n\n By: /s/ Jordan A. Cafritz\n Jordan A. Cafritz (Bar #:20908)\n 1101 Vermont Ave., NW Suite 800\n Washington, D.C. 20005\n Tel: (202) 524-4290\n Fax: (202) 333-2121\n Email: jcafritz@zlk.com\n\n LEVI & KORSINSKY, LLP\n Adam M. Apton (pro hac vice forthcoming)\n 33 Whitehall Street, 27th Floor\n New York, NY 10004\n Tel: (212) 363-7500\n Fax: (212) 363-7171\n Email: aapton@zlk.com\n\n Lead Counsel for Carlos Rios and\n [Proposed] Lead Counsel for the Class\n\n\n\n\n 12\n\f Case 8:25-cv-02581-TDC Document 13-1 Filed 10/06/25 Page 13 of 13\n\n\n\n CERTIFICATE OF SERVICE\n\n\n I, Jordan A. Cafritz, hereby certify that this document was filed through the CM/ECF\n\nsystem and will be sent electronically to the registered participants as identified on the Notice of\n\nElectronic Filing (NEF) on this 6th day of October 2025.\n\n /s/ Jordan A. Cafritz\n Jordan A. Cafritz\n\n\n\n\n 13\n\f","ocr_status":2,"date_upload":"2026-05-18T06:04:47.185754-07:00","document_number":"13","attachment_number":1,"pacer_doc_id":"093015216078","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Memorandum in Support","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528532/","id":479528532,"tags":[],"absolute_url":"/docket/71033169/13/2/collier-v-altimmune-inc/","date_created":"2026-05-18T06:04:32.869025-07:00","date_modified":"2026-05-22T03:28:32.309159-07:00","sha1":"4a4f445cd505fadce224cddb98736c2d2eb3ac02","page_count":3,"file_size":149518,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":"2026-05-18T06:04:48.084973-07:00","document_number":"13","attachment_number":2,"pacer_doc_id":"093015216079","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Affidavit of Jordan A. Cafritz","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528533/","id":479528533,"tags":[],"absolute_url":"/docket/71033169/13/3/collier-v-altimmune-inc/","date_created":"2026-05-18T06:04:32.882497-07:00","date_modified":"2026-05-22T03:48:43.415628-07:00","sha1":"a526b343981f0972d1b719cfc88c7f1586714285","page_count":3,"file_size":625546,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 13-3 Filed 10/06/25 Page 1 of 3\n\n\n\n\n EXHIBIT A\n\f Case 8:25-cv-02581-TDC Document 13-3 Filed 10/06/25 Page 2 of 3\n\n\n\n Certification of Plaintiff Pursuant to Federal Securities Laws\n\n I, Carlos Rios, duly certify and say, as to the claims asserted under the federal securities\nlaws, that:\n\n 1. I have reviewed a complaint filed in the action.\n\n 2. I did not purchase the security that is the subject of this action at the direction of\nplaintiff's counsel or in order to participate in this action.\n\n 3. I am willing to serve as a representative party on behalf of the class, including\nproviding testimony at deposition and trial, if necessary.\n\n 4. My transaction(s) in Altimmune, Inc. which are the subject of this litigation during the\nclass period set forth in the complaint are set forth in the chart attached hereto.\n\n 5. Within the last 3 years, I have not sought to serve nor have I served as a class\nrepresentative in any federal securities fraud case.\n\n 6. I will not accept any payment for serving as a representative party on behalf of the\nclass beyond the Plaintiff's pro rata share of any recovery, except as ordered or approved by the\ncourt, including any award for reasonable costs and expenses (including lost wages) directly\nrelating to the representation of the class.\n I certify under penalty of perjury under the laws of the United States of America that the\nforegoing is true and correct. Executed this:\n\nDate: Sep 26, 2025\nName: Carlos Rios\n\nSignature:\n\f Case 8:25-cv-02581-TDC Document 13-3 Filed 10/06/25 Page 3 of 3\n\n\n\n\nCase Name Altimmune, Inc.\nTicker ALT\nClass Period 08-10-2023 to 06-25-2025\n\nClient Name\nCarlos Rios\n\n Date of Transaction Transaction Type Quantity Price per Share\n 06-04-2024 P 2200 $ 07.7089\n 06-04-2024 P 4400 $ 07.7800\n 06-14-2024 P 3400 $ 06.1450\n 06-24-2024 P 5000 $ 07.7300\n 09-13-2024 P 2000 $ 07.8298\n 10-08-2024 P 3000 $ 06.2483\n 10-09-2024 P 2000 $ 06.0989\n 11-14-2024 P 3000 $ 08.7383\n 11-14-2024 P 23000 $ 08.5900\n 11-14-2024 S -26000 $ 08.7248\n 12-02-2024 S -2000 $ 08.6550\n 03-14-2025 S -3900 $ 05.6118\n 05-08-2025 P 2900 $ 05.8697\n 06-02-2025 S -4000 $ 05.1901\n 06-04-2025 P 3000 $ 05.4885\n 06-05-2025 S -3000 $ 05.4809\n 06-09-2025 P 1000 $ 05.7177\n 06-10-2025 P 500 $ 06.1590\n 06-10-2025 P 2500 $ 06.1500\n 06-10-2025 P 1000 $ 06.3880\n 06-13-2025 P 1000 $ 07.2449\n 06-16-2025 P 2000 $ 07.2898\n 06-23-2025 P 700 $ 06.9280\n 06-24-2025 P 300 $ 07.0072\n 06-25-2025 P 1000 $ 06.9699\n\f","ocr_status":1,"date_upload":"2026-05-18T06:04:53.259001-07:00","document_number":"13","attachment_number":3,"pacer_doc_id":"093015216080","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit A- PSLRA Certification","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528534/","id":479528534,"tags":[],"absolute_url":"/docket/71033169/13/4/collier-v-altimmune-inc/","date_created":"2026-05-18T06:04:32.893859-07:00","date_modified":"2026-05-22T03:47:39.304448-07:00","sha1":"1a5bddcee209da437705cb41da174cc3f1b08a8a","page_count":2,"file_size":579505,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.4.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 13-4 Filed 10/06/25 Page 1 of 2\n\n\n\n\n EXHIBIT B\n\f Case 8:25-cv-02581-TDC Document 13-4 Filed 10/06/25 Page 2 of 2\n\n\n Client Name Carlos Rios\n Company Name Altimmune, Inc. SUMMARY OF FINANCIAL INTEREST\n Ticker Symbol ALT LIFO Loss Total $79,449.72\n Security Type DURA LIFO* Total $70,606.15\n Class Period Start 8/10/2023 Gross Shares Purchased 63,900\n Class Period End 6/25/2025 Net Shares Retained 25,000\n 90-DAY Lookback Period Start 6/26/2025 Net Funds Expended $177,672.48\n 90-DAY Lookback Period End 9/24/2025\n 90-DAY Lookback Average $ 03.85\n\n\n\n\n Purchases Sales Retained Losses\n Shares\n Shares\n Shares Purchased During Trade Shares Sold Shares Sold Price Per Proceeds from Proceeds from Retained Per Share\n Trade Date Price Per Share Total Cost Retained at Retained Value LIFO DURA LIFO*\n the CP Date During the CP During the LBP1 Share2 CP Sales LBP Sales at End of Value\n End of LBP\n CP\n 06-04-2024 2200 7.7089 $ 16,959.58 - 2200 2200 $ 03.85 $ 8,472.10 $ 8,487.48 $ 8,487.48\n 06-04-2024 1600 7.78 $ 12,448.00 08-07-2025 1600 $ 04.08 $ 6,528.00 1600 - $ 03.85 $ 5,920.00 $ 5,920.00\n 06-04-2024 2800 7.78 $ 21,784.00 - 2800 2800 $ 03.85 $ 10,782.67 $ 11,001.33 $ 11,001.33\n 06-14-2024 2500 6.145 $ 15,362.50 07-24-2025 2500 $ 04.23 $ 10,575.00 2500 - $ 03.85 $ 4,787.50 $ 4,787.50\n 06-14-2024 900 6.145 $ 5,530.50 08-07-2025 900 $ 04.08 $ 3,672.00 900 - $ 03.85 $ 1,858.50 $ 1,858.50\n 06-24-2024 5000 7.73 $ 38,650.00 07-07-2025 5000 $ 04.40 $ 22,003.00 5000 - $ 03.85 $ 16,647.00 $ 16,647.00\n 09-13-2024 900 7.8298 $ 7,046.82 03-14-2025 900 $ 05.61 $ 5,050.62 - - - $ 03.85 $ 1,996.20\n 09-13-2024 1100 7.8298 $ 8,612.78 06-02-2025 1100 $ 05.19 $ 5,709.11 - - - $ 03.85 $ 2,903.67\n 10-08-2024 3000 6.2483 $ 18,744.90 03-14-2025 3000 $ 05.61 $ 16,835.40 - - - $ 03.85 $ 1,909.50\n 10-09-2024 2000 6.0989 $ 12,197.80 12-02-2024 2000 $ 08.66 $ 17,310.00 - - - $ 03.85 -$ 5,112.20 -$ 5,112.20\n 11-14-2024 3000 8.7383 $ 26,214.90 11-14-2024 3000 $ 08.72 $ 26,174.25 - - - $ 03.85 $ 40.65\n 11-14-2024 23000 8.58998 $ 197,569.54 11-14-2024 23000 $ 08.72 $ 200,669.25 - - - $ 03.85 -$ 3,099.71 -$ 3,099.71\n 05-08-2025 2900 5.86969 $ 17,022.10 06-02-2025 2900 $ 05.19 $ 15,051.29 - - - $ 03.85 $ 1,970.81\n 06-04-2025 3000 5.4885 $ 16,465.50 06-05-2025 3000 $ 05.48 $ 16,442.76 - - - $ 03.85 $ 22.74\n 06-09-2025 1000 5.7177 $ 5,717.70 06-27-2025 1000 $ 03.62 $ 3,620.00 1000 - $ 03.85 $ 2,097.70 $ 2,097.70\n 06-10-2025 500 6.159 $ 3,079.50 06-27-2025 500 $ 03.62 $ 1,810.00 500 - $ 03.85 $ 1,269.50 $ 1,269.50\n 06-10-2025 2000 6.15 $ 12,300.00 06-27-2025 2000 $ 03.63 $ 7,260.00 2000 - $ 03.85 $ 5,040.00 $ 5,040.00\n 06-10-2025 500 6.15 $ 3,075.00 06-27-2025 500 $ 03.62 $ 1,810.00 500 - $ 03.85 $ 1,265.00 $ 1,265.00\n 06-10-2025 1000 6.38798 $ 6,387.98 06-27-2025 1000 $ 03.63 $ 3,630.00 1000 - $ 03.85 $ 2,757.98 $ 2,757.98\n 06-13-2025 1000 7.2449 $ 7,244.90 06-27-2025 1000 $ 03.63 $ 3,630.00 1000 - $ 03.85 $ 3,614.90 $ 3,614.90\n 06-16-2025 1000 7.28975 $ 7,289.75 06-27-2025 1000 $ 03.60 $ 3,600.00 1000 - $ 03.85 $ 3,689.75 $ 3,689.75\n 06-16-2025 1000 7.28975 $ 7,289.75 06-27-2025 1000 $ 03.63 $ 3,630.00 1000 - $ 03.85 $ 3,659.75 $ 3,659.75\n 06-23-2025 700 6.928 $ 4,849.60 06-27-2025 700 $ 03.60 $ 2,520.00 700 - $ 03.85 $ 2,329.60 $ 2,329.60\n 06-24-2025 300 7.0072 $ 2,102.16 06-27-2025 300 $ 03.60 $ 1,080.00 300 - $ 03.85 $ 1,022.16 $ 1,022.16\n 06-25-2025 1000 6.9699 $ 6,969.90 06-27-2025 1000 $ 03.60 $ 3,600.00 1000 - $ 03.85 $ 3,369.90 $ 3,369.90\n Total: 63,900 $480,915.16 38,900 20000 $303,242.68 $78,968 25,000 5,000 $19,254.76 $79,449.72 $70,606.15\n\n\n\n\nLegend: Class Period (CP); Lookback Period (LbP); Last-In-First-Out (LIFO)\n\n1 Sales during the LbP are matched to class period purchases utilizing LIFO.\n2 Post-class period sales valued using the greater of: (1) the average closing price between the end of the class period and the sales date; or (2) the actual sales price.\n* Disregarding losses not attributable to the alleged fraud from intra-class period sales made prior to any corrective disclosure matched to intra-class period purchases.\n\f","ocr_status":1,"date_upload":"2026-05-18T06:05:00.002761-07:00","document_number":"13","attachment_number":4,"pacer_doc_id":"093015216081","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit B- Loss Chart","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528535/","id":479528535,"tags":[],"absolute_url":"/docket/71033169/13/5/collier-v-altimmune-inc/","date_created":"2026-05-18T06:04:32.904657-07:00","date_modified":"2026-05-22T03:28:36.199021-07:00","sha1":"e5a4a803270fbbaf218751771dbe5f35c0b5c5e1","page_count":3,"file_size":398890,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.5.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.5.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document13-5 Filed 10/06/25 Pagelof3\n\nEXHIBIT C\n\fDocument 13-5 Filed 10/06/25 Page 2 of 3\n\nSource: Levi & Korsinsky, LLP\n\nAugust 05, 2025 19:06 ET\n\nSHAREHOLDER ALERT: Levi &\nKorsinsky, LLP Notifies\nInvestors It Has Filed a\nComplaint to Recover Losses\nSuffered by Purchasers of\nAltimmune, Inc. Securities\nand Sets a Lead Plaintiff\nDeadline of October 6, 2025\n\nNEW YORK, Aug. 05, 2025 (GLOBE NEWSWIRE) -- The following statement is being issued by Levi &\nKorsinsky, LLP:\n\nTo: All persons or entities who purchased or otherwise acquired securities of Altimmune, Inc.\n\nboth dates inclusive. You are hereby notified that the class action lawsuit Dave Collier v.\nAltimmune, Inc. et al. (Case No. 8:25-cv-02581) has been commenced in the United States District\n\nCourt for the District of Maryland. To get more information go to:\n\nhttps:/zlk.com/pslra-1/altimmune-inc-lawsuit-submission-form-2\n\nor contact Joseph E. Levi, Esq. either via email at jlevi@levikorsinsky.com or by telephone at (212)\n363-7500. There is no cost or obligation to you.\n\nAccording to the complaint, on June 26, 2025, Altimmune published a press release announcing\ntopline results from the IMPACT Phase 2b MASH trial of Pemvidutide in the Treatment of MASH.\nWhile defendants had continuously provided inflated expectations ahead of these results, the\n\fanalysis showed a pointed failure by the Company to achieve statistical significance in its analysis of\nthe fibrosis redu por its IMPACT pas BANA or| In parti euler while a\npositive tre asin Feecae Paeh pas Cypser, SB otisel Bad Pa pr et due toa\nhigher-than-expected placebo response. When questioned eal this concerning miss, defendants\n\nanswered indifferently, attributing this result to the Phase 2 nature of the trial and stated that\nAltimmune was hoping for better results following the Phase 3 trial.\n\nFollowing this news, the price of Altimmune\u2019s common stock declined dramatically. From a closing\nmarket price of $7.71 per share on June 25, 2025, Altimmune's stock price fell to $3.61 per share on\nJune 26, 2025, a decline of 53.2% in the span of just a single day.\n\nIf you suffered a loss in ALT securities, you have until October 6, 2025 to request that the Court\nappoint you as lead plaintiff. Your ability to share in any recovery doesn't require that you serve asa\nlead plaintiff.\n\nWHY LEVI & KORSINSKY: Over the past 20 years, the team at Levi & Korsinsky has secured\nhundreds of millions of dollars for aggrieved shareholders and built a track record of winning high-\nstakes cases. Our firm has extensive expertise representing investors in complex securities litigation\nand a team of over 70 employees to serve our clients. For seven years in a row, Levi & Korsinsky has\nranked in ISS Securities Class Action Services\u2019 Top 50 Report as one of the top securities litigation\nfirms in the United States.\n\nCONTACT:\n\nLevi & Korsinsky, LLP\n\nJoseph E. Levi, Esq.\n\nEd Korsinsky, Esq.\n\n33 Whitehall Street, 27th Floor\nNew York, NY 10004\njlevi@levikorsinsky.com\n\nTel: (212) 363-7500\n\nFax: (212) 363-7171\nwww.zik.com\n","ocr_status":1,"date_upload":"2026-05-18T06:05:02.036247-07:00","document_number":"13","attachment_number":5,"pacer_doc_id":"093015216082","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit C- PSLRA Notice","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528536/","id":479528536,"tags":[],"absolute_url":"/docket/71033169/13/6/collier-v-altimmune-inc/","date_created":"2026-05-18T06:04:32.921840-07:00","date_modified":"2026-05-22T03:24:33.037338-07:00","sha1":"e0f4391b6d7713a9851756e654bc0ecce398a048","page_count":3,"file_size":239549,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.6.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.6.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":"2026-05-18T06:05:23.087104-07:00","document_number":"13","attachment_number":6,"pacer_doc_id":"093015216083","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit D- Movant Declaration","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528537/","id":479528537,"tags":[],"absolute_url":"/docket/71033169/13/7/collier-v-altimmune-inc/","date_created":"2026-05-18T06:04:32.933130-07:00","date_modified":"2026-05-22T03:35:36.535203-07:00","sha1":"09973959fd3f84775f0af899e94b328c1ec09dee","page_count":82,"file_size":3401573,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.7.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.7.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":"2026-05-18T06:05:15.704789-07:00","document_number":"13","attachment_number":7,"pacer_doc_id":"093015216084","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit E- Firm Resume","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479528538/","id":479528538,"tags":[],"absolute_url":"/docket/71033169/13/8/collier-v-altimmune-inc/","date_created":"2026-05-18T06:04:32.944288-07:00","date_modified":"2026-05-22T03:29:04.120840-07:00","sha1":"cf797d8827c40411af906da3878baddd7d4e277b","page_count":4,"file_size":163634,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.8.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.13.8.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 13-8 Filed 10/06/25 Page 1 of 4\n\n\n\n UNITED STATES DISTRICT COURT\n DISTRICT OF MARYLAND\n\nDAVE COLLIER, Individually and on Behalf\nof All Others Similarly Situated,\n\n Plaintiff,\n Case No.: 8:25-cv-02581-TDC\nv.\n Hon. Theodore D. Chuang\nALTIMMUNE, INC., VIPIN K. GARG, and\nMATTHEW SCOTT HARRIS,\n\n Defendants.\n\n\n [PROPOSED] ORDER GRANTING THE MOTION OF CARLOS RIOS\n FOR APPOINTMENT AS LEAD PLAINTIFF AND\n APPROVAL OF SELECTION OF COUNSEL\n\n WHEREAS, in accordance with the provisions of Section 21D(a)(3)(A)(i) of the Exchange\n\nAct, on August 5, 2025, notice of the Lead Plaintiff deadline was published in Globe Newswire, a\n\nwidely circulated national business-oriented wire service, advising Class members of the pendency\n\nof the class action, the claims asserted therein, the purported Class Period, and their right to move\n\nthis Court to be appointed Lead Plaintiff; and\n\n WHEREAS, pursuant to Section 21D of the Exchange Act, any purported Class member\n\ndesiring to be appointed Lead Plaintiff was required to have filed a motion for such appointment\n\non or before October 6, 2025; and\n\n WHEREAS, Movant Carlos Rios (\u201cMovant\u201d) filed a timely motion to be appointed Lead\n\nPlaintiff; and\n\n WHEREAS, Movant has the largest financial interest in the relief sought by the Class and\n\notherwise satisfies the requirements of Section 21D of the Exchange Act and Rule 23 of the Federal\n\nRules of Civil Procedure; and\n\f Case 8:25-cv-02581-TDC Document 13-8 Filed 10/06/25 Page 2 of 4\n\n\n\n WHEREAS, in accordance with Section 21D (a)(3)(B)(v) of the Exchange Act, 15 U.S.C.\n\n\u00a7 78u-4(a)(3)(B)(v), Movant seeks approval of his selection of counsel to serve as Lead Counsel\n\nfor the Class.\n\n AND NOW THIS _______ day of _________________ 2025, the Court having considered\n\nMovant\u2019s Motion for Appointment as Lead Plaintiff and Approval of her Selection of Counsel as\n\nLead Counsel, and all supporting documents, and good cause appearing therefore, it is hereby\n\nORDERED as follows:\n\n NEWLY FILED OR TRANSFERRED ACTIONS\n\n 1. When a case that arises out of the subject matter of this action is hereinafter filed\n\nin this Court or transferred to this Court from another Court, the clerk of this Court shall:\n\n a. File a copy of this Order in the separate file for such action;\n\n b. Mail a copy of this Order to the attorneys for the plaintiff(s) in the newly filed or\n\n transferred case and to any new defendant(s) in the newly filed or transferred case;\n\n and\n\n c. Make the appropriate entry in the docket for this action.\n\n 2. Each new case arising out of the subject matter of this Action that is filed in this\n\nCourt or transferred to this Court shall be consolidated with this action and this Order shall apply\n\nthereto, unless a party objecting to this Order or any provision of this Order shall, within ten (10)\n\ndays after the date upon which a copy of this Order is served on counsel for such party, files an\n\napplication for relief from this Order or any provision herein and this Court deems it appropriate\n\nto grant such application.\n\n 3. During the pendency of this litigation, or until further order of this Court, the parties\n\nshall take reasonable steps to preserve all documents within their possession, custody or control,\n\n\n\n\n 2\n\f Case 8:25-cv-02581-TDC Document 13-8 Filed 10/06/25 Page 3 of 4\n\n\n\nincluding computer-generated and stored information and materials such as computerized data and\n\nelectronic mail, containing information that is relevant to or may lead to the discovery of\n\ninformation relevant to the subject matter of the pending litigation.\n\n LEAD PLAINTIFF APPOINTMENT\n\n 4. The motion of Movant to serve as Lead Plaintiff in the Action is GRANTED.\n\nPursuant to Section 21D of the Exchange Act, 15 U.S.C. \u00a778u-4(a)(3)(B), Movant is appointed as\n\nLead Plaintiff for the Class.\n\n LEAD COUNSEL\n\n 5. Pursuant to Section 21D(a)(3)(B)(v) of the PSLRA, 15 U.S.C. \u00a7 78u- 4(a)(3)(B)(v),\n\nMovant has selected and retained the law firm of Levi & Korsinsky, LLP to serve as Lead Counsel\n\nin the Action. The Court approves Movant\u2019s selection of Lead Counsel.\n\n 6. Lead Counsel shall have the following responsibilities and duties, to be carried out\n\neither personally or through counsel whom Lead Counsel shall designate:\n\n a. to coordinate the briefing and argument of any and all motions;\n\n b. to coordinate the conduct of any and all discovery proceedings;\n\n c. to coordinate the examination of any and all witnesses in depositions;\n\n d. to coordinate the selection of counsel to act as spokesperson at all pretrial\n\n conferences;\n\n e. to coordinate all settlement negotiations with counsel for defendants;\n\n f. to coordinate and direct the pretrial discovery proceedings and the preparation for\n\n trial and the trial of this matter, and to delegate work responsibilities to selected\n\n counsel as may be required;\n\n g. to coordinate the preparation and filings of all pleadings; and to supervise all other\n\n\n\n\n 3\n\f Case 8:25-cv-02581-TDC Document 13-8 Filed 10/06/25 Page 4 of 4\n\n\n\n matters concerning this litigation.\n\n 7. No settlement negotiations shall be conducted without the approval of Lead\n\nCounsel.\n\n 8. Lead Counsel shall have responsibility for receiving and disseminating Court\n\norders and notices.\n\n 9. Lead Counsel shall be the contact between the class and defendants\u2019 counsel, shall\n\nserve as the spokespersons for the class. Lead Counsel shall act as the liaison between the Court\n\nand the class.\n\n IT IS SO ORDERED.\n\n Dated: __________________, 2025\n THE HONORABLE THEODORE D. CHUANG\n UNITED STATES DISTRICT JUDGE\n\n\n\n\n 4\n\f","ocr_status":2,"date_upload":"2026-05-18T06:05:25.301202-07:00","document_number":"13","attachment_number":8,"pacer_doc_id":"093015216085","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Text of Proposed Order","acms_document_guid":""}],"date_created":"2025-12-01T00:06:50.087889-08:00","date_modified":"2026-07-12T22:47:08.642410-07:00","date_filed":"2025-10-06","time_filed":null,"entry_number":13,"recap_sequence_number":"2025-10-06.005","pacer_sequence_number":43,"description":"MOTION to Appoint Counsel and Appoint Lead Plaintiff by Carlos Rios (Attachments: # 1 Memorandum in Support, # 2 Affidavit of Jordan A. Cafritz, # 3 Exhibit A- PSLRA Certification, # 4 Exhibit B- Loss Chart, # 5 Exhibit C- PSLRA Notice, # 6 Exhibit D- Movant Declaration, # 7 Exhibit E- Firm Resume, # 8 Text of Proposed Order)(Cafritz, Jordan) (Entered: 10/06/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/445672459/","id":445672459,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71033169/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/460378079/","id":460378079,"tags":[],"absolute_url":"/docket/71033169/12/collier-v-altimmune-inc/","date_created":"2025-12-01T00:06:50.036090-08:00","date_modified":"2026-07-12T22:47:08.618552-07:00","sha1":"e550c5af34fb01f17708c6c061c55f9b222acc53","page_count":3,"file_size":114180,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 12 Filed 10/06/25 Page 1 of 3\n\n\n\n\n UNITED STATES DISTRICT COURT\n DISTRICT OF MARYLAND\n (Southern Division)\n\n\n DAVE COLLIER, Individually and on Case No: 8:25-cv-02581-TDC\n Behalf of All Others Similarly Situated,\n\n Plaintiff,\n CLASS ACTION\n v.\n\n ALTIMMUNE, INC., VIPIN K. GARG,\n and MATTHEW SCOTT HARRIS,\n\n Defendants.\n\n\n\n DECLARATION OF PHILLIP KIM IN SUPPORT OF CONNOR MCCREERY\n\n APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF HIS SELECTION OF\n\n COUNSEL\n\nI, Phillip Kim, declare:\n\n 1. I am a partner at The Rosen Law Firm, P.A., proposed Lead Counsel for Movant\n\nConnor McCreery (\u201cMovant\u201d). I make this Declaration in support of the motion of Movant for:\n\n(1) appointment of Movant as the Lead Plaintiff for the Class; (2) approval of Movant\u2019s choice\n\nof counsel, The Rosen Law Firm, P.A. as Lead Counsel; and(3) granting such other and further\n\nrelief as the Court may deem just and proper (the \u201cMotion\u201d).\n\n 2. Attached hereto as the exhibits indicated are true and correct copies of the\n\nfollowing:\n\n Exhibit 1: PSLRA early notice issued on August 5, 2025;\n\n Exhibit 2: Movant\u2019s PSRLA Certification;\n\n\n 1\n\f Case 8:25-cv-02581-TDC Document 12 Filed 10/06/25 Page 2 of 3\n\n\n\n Exhibit 3: Movant\u2019s Loss Chart;\n\n Exhibit 4: The Rosen Law Firm, P.A.\u2019s firm resume; and\n\n I declare under penalty of perjury under the laws of the United States of America\n\nthat to the best of my knowledge the foregoing facts are true and correct.\n\n Executed this 6th day of October, 2025.\n\n\n /s/ Phillip Kim\n Phillip Kim\n\n\n\n\n 2\n\f Case 8:25-cv-02581-TDC Document 12 Filed 10/06/25 Page 3 of 3\n\n\n\n\n CERTIFICATE OF SERVICE\n\nI hereby certify that on October 6, 2025, a true and correct copy of the foregoing document was\n served by CM/ECF to the parties registered to the Court\u2019s CM/ECF system.\n\n /s/ Phillip Kim\n\n\n\n\n 3\n\f","ocr_status":1,"date_upload":"2026-05-18T06:05:20.373518-07:00","document_number":"12","attachment_number":null,"pacer_doc_id":"093015216054","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479529128/","id":479529128,"tags":[],"absolute_url":"/docket/71033169/12/1/collier-v-altimmune-inc/","date_created":"2026-05-18T06:05:23.446834-07:00","date_modified":"2026-05-22T03:44:12.538988-07:00","sha1":"f8191dc358bd5b44c9333a3351e61703114ed317","page_count":3,"file_size":139683,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 12-1 Filed 10/06/25 Page 1 of 3\n\n\n\n\n Exhibit 1\n\f Case 8:25-cv-02581-TDC Document 12-1 Filed 10/06/25 Page 2 of 3\n\n\n\n\nSource: Levi & Korsinsky, LLP\nAugust 05, 2025 19:06 ET\n\n\n\n\nSHAREHOLDER ALERT: Levi &\nKorsinsky, LLP Notifies\nInvestors It Has Filed a\nComplaint to Recover Losses\nSuffered by Purchasers of\nAltimmune, Inc. Securities\nand Sets a Lead Plaintiff\nDeadline of October 6, 2025\nNEW YORK, Aug. 05, 2025 (GLOBE NEWSWIRE) -- The following statement is being issued by Levi &\nKorsinsky, LLP:\nTo: All persons or entities who purchased or otherwise acquired securities of Altimmune, Inc.\n(\u201cAltimmune\u201d or the \u201cCompany\u201d) (NASDAQ: ALT) between August 10, 2023 and June 25, 2025,\nboth dates inclusive. You are hereby notified that the class action lawsuit Dave Collier v.\nAltimmune, Inc., et al. (Case No. 8:25-cv-02581) has been commenced in the United States District\nCourt for the District of Maryland. To get more information go to:\n https://zlk.com/pslra-1/altimmune-inc-lawsuit-submission-form-2\nor contact Joseph E. Levi, Esq. either via email at jlevi@levikorsinsky.com or by telephone at (212)\n363-7500. There is no cost or obligation to you.\nAccording to the complaint, on June 26, 2025, Altimmune published a press release announcing\ntopline results from the IMPACT Phase 2b MASH trial of Pemvidutide in the Treatment of MASH.\nWhile defendants had continuously provided inflated expectations ahead of these results, the\n\fanalysis showed a pointed failure by the Company to achieve statistical significance in its analysis of\nthe fibrosis reduction primary endpoint in its IMPACT Phase 2b MASH trial. In particular, while a\n Case 8:25-cv-02581-TDC Document 12-1 Filed 10/06/25 Page 3 of 3\npositive trend in fibrosis improvement was observed, statistical significance was not met due to a\nhigher-than-expected placebo response. When questioned about this concerning miss, defendants\nanswered indifferently, attributing this result to the Phase 2 nature of the trial and stated that\nAltimmune was hoping for better results following the Phase 3 trial.\nFollowing this news, the price of Altimmune\u2019s common stock declined dramatically. From a closing\nmarket price of $7.71 per share on June 25, 2025, Altimmune\u2019s stock price fell to $3.61 per share on\nJune 26, 2025, a decline of 53.2% in the span of just a single day.\nIf you suffered a loss in ALT securities, you have until October 6, 2025 to request that the Court\nappoint you as lead plaintiff. Your ability to share in any recovery doesn\u2019t require that you serve as a\nlead plaintiff.\nWHY LEVI & KORSINSKY: Over the past 20 years, the team at Levi & Korsinsky has secured\nhundreds of millions of dollars for aggrieved shareholders and built a track record of winning high-\nstakes cases. Our firm has extensive expertise representing investors in complex securities litigation\nand a team of over 70 employees to serve our clients. For seven years in a row, Levi & Korsinsky has\nranked in ISS Securities Class Action Services\u2019 Top 50 Report as one of the top securities litigation\nfirms in the United States.\nCONTACT:\nLevi & Korsinsky, LLP\nJoseph E. Levi, Esq.\nEd Korsinsky, Esq.\n33 Whitehall Street, 27th Floor\nNew York, NY 10004\njlevi@levikorsinsky.com\nTel: (212) 363-7500\nFax: (212) 363-7171\nwww.zlk.com\n\f","ocr_status":2,"date_upload":"2026-05-18T06:05:38.983422-07:00","document_number":"12","attachment_number":1,"pacer_doc_id":"093015216055","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 1. PSLRA Notice","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479529129/","id":479529129,"tags":[],"absolute_url":"/docket/71033169/12/2/collier-v-altimmune-inc/","date_created":"2026-05-18T06:05:23.461468-07:00","date_modified":"2026-05-22T03:44:16.310588-07:00","sha1":"727a559dcf308487c862c9714e023b428e9009f1","page_count":4,"file_size":236795,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document12-2 Filed 10/06/25 Page1of4\n\nExhibit 2\n\fCase 8:25-cv-02581-TDC Document12-2 Filed 10/06/25 Page 2of4\n\nCertification and Authorization of Named Plaintiff Pursuant to Federal\nSecurities Laws\n\nThe individual or institution listed below (the \"Plaintiff') authorizes and, upon execution of the accompanying\nretainer agreement by The Rosen Law Firm P.A., retains The Rosen Law Firm P.A. to file an action under the\nfederal securities laws to recover damages and to seek other relief against Altimmune, Inc. The Rosen Law Firm\nP.A. will prosecute the action on a contingent fee basis not to exceed one-third of the recovery and will advance all\ncosts and expenses. All payments of fees and expenses shall be made only after Court review and approval. The\nAltimmune, Inc. Retention Agreement provided to the Plaintiff is incorporated by reference herein and is effective,\nupon execution and delivery by The Rosen Law Firm P.A.\n\nFirst Name:\nMiddle Initial:\nLast Name:\nMailing Address: INCclel-leit-le p\nCity:\n\nState:\n\nZip Code:\nCountry:\nPhone:\n\nEmail Address:\n\nPlaintiff certifies that:\n\n1. Plaintiff has reviewed a complaint and authorized its filing or the filing of an amended complaint.\n2. Plaintiff did not acquire the security that is the subject of this action at the direction of plaintiff's counsel or in\norder to participate in this private action or any other litigation under the federal securities laws.\n3. Plaintiff is willing to serve as a representative party on behalf of a class, including providing testimony at\ndeposition and trial, if necessary.\n. Plaintiff represents and warrants that he/she/it is fully authorized to enter into and execute this certification.\n. Plaintiff will not accept any payment for serving as a representative party on behalf of the class beyond\nPlaintiffs pro rata share of any recovery, except such reasonable costs and expenses (including lost\nwages) directly relating to the representation of the class as ordered or approved by the court.\n6. Plaintiff has made no transaction(s) during the Class Period in the debt or equity securities that are the\nsubject of this action except those set forth below:\n\naf\n\nPurchases:\n\nType of Security Buy Date no of Shares Price per Share\n\nCc Stock\nommon stoc See attached Schedule A.\n\nType of Security Buy Date no of Shares Price per Share\nCommon Stock\n\nSales:\n\nType of Security Sale Date no of Shares Price per Share\nCommon Stock\n\nType of Security Sale Date no of Shares Price per Share\n\n\fCase 8:25-cv-02581-TDC Document12-2 Filed 10/06/25 Page 3of4\n\nCommon Stock\n\n| have not sought to serve as a representative party on behalf of a class under the federal securities laws\nduring the last three years, except if set forth below.\nNot applicable\n\n| declare and certify under penalty of perjury, under the laws of the United States YES\nof America, that the foregoing information is true and correct.\n\nBy Signing below and submitting this certification form electronically, |intendto YES\nsign and execute this certification pursuant to California Civil Code Section\n\n1633.1, et seq. - and the Uniform Electronic Transactions Act and retain the\n\nRosen Law Firm, P.A. to proceed on Plaintiff's behalf, on a contingent fee basis.\n\nDate of signing: 08/26/2025 11:26:25 at Eastern Standard Time, USA\n\n2/2\n\fCase 8:25-cv-02581-TDC Document12-2 Filed 10/06/25 Page4of4\n\nSCHEDULE A\n\nCONNOR MCCREERY TRANSACTIONS\nBETWEEN AUGUST 10, 2023 AND JUNE 25, 2025\n\nDate Shares Price per Date Sold Shares Price per\nPurchased Share Share\n5/12/2025 474 ($6.07) 6/23/2025 5 $7.06\n6/16/2025 50 ($6.95) 6/23/2025 135 $6.95\n6/16/2025 830 ($6.94) 6/23/2025 10 $6.97\n6/18/2025 260 ($6.86)\n\n6/18/2025 76 ($6.86)\n\n6/18/2025 1300 ($6.86)\n\n6/18/2025 9 ($6.86)\n\n6/18/2025 670 ($6.86)\n\n6/19/2025 125 ($6.86)\n\n6/19/2025 1250 ($6.86)\n\n6/19/2025 7 ($6.86)\n\n6/19/2025 700 ($6.86)\n\n6/20/2025 5 ($6.79)\n\n6/20/2025 32 ($6.77)\n\n6/20/2025 100 ($6.77)\n\n6/20/2025 20 ($6.76)\n\n6/20/2025 100 ($6.79)\n\n6/20/2025 3 ($6.86)\n\n6/23/2025 14 ($6.99)\n\n6/23/2025 130 ($6.97)\n\n6/23/2025 3 ($6.90)\n\n6/23/2025 30 ($6.96)\n\n6/23/2025 75 ($6.94)\n\n6/23/2025 200 ($6.88)\n\n6/23/2025 1350 ($6.85)\n\n","ocr_status":1,"date_upload":"2026-05-18T06:07:18.026503-07:00","document_number":"12","attachment_number":2,"pacer_doc_id":"093015216056","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 2. PSLRA Certification","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479529130/","id":479529130,"tags":[],"absolute_url":"/docket/71033169/12/3/collier-v-altimmune-inc/","date_created":"2026-05-18T06:05:23.474674-07:00","date_modified":"2026-05-22T03:41:38.508128-07:00","sha1":"f5199c500cc1e6760393aa97d0b149b1af4a92e5","page_count":2,"file_size":417019,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 12-3 Filed 10/06/25 Page 1 of 2\n\n\n\n\n Exhibit 3\n\f Case 8:25-cv-02581-TDC Document 12-3 Filed 10/06/25 Page 2 of 2\n\n Altimmune, Inc. Loss Chart Lookback\n Class Period: August 10, 2023 through June 25, 2025, both dates inclusive Price\nName Date Shares Price per Total Date Sold Shares Price per Total Shares Value Total Loss/Gain $3.85\n Purchased Share Share Retained Retained\nConnor 5/12/2025 474 ($6.07) ($2,877.18) 6/23/2025 5 $7 06 $35.30\nMcCreery\n 6/16/2025 50 ($6.95) ($347 50) 6/23/2025 135 $6 95 $938.25\n 6/16/2025 830 ($6.94) ($5,760.20) 6/23/2025 10 $6 97 $69.70\n 6/18/2025 260 ($6.86) ($1,783.60)\n 6/18/2025 76 ($6.86) ($521 36)\n 6/18/2025 1300 ($6.86) ($8,918.00)\n 6/18/2025 9 ($6.86) ($61.74)\n 6/18/2025 670 ($6.86) ($4,596.20)\n 6/19/2025 125 ($6.86) ($857 50)\n 6/19/2025 1250 ($6.86) ($8,575.00)\n 6/19/2025 7 ($6.86) ($48.02)\n 6/19/2025 700 ($6.86) ($4,802.00)\n 6/20/2025 5 ($6.79) ($33.95)\n 6/20/2025 32 ($6.77) ($216.64)\n 6/20/2025 100 ($6.77) ($677 00)\n 6/20/2025 20 ($6.76) ($135 20)\n 6/20/2025 100 ($6.79) ($679 00)\n 6/20/2025 3 ($6.86) ($20.58)\n 6/23/2025 14 ($6.99) ($97.86)\n 6/23/2025 130 ($6.97) ($906.10)\n 6/23/2025 3 ($6.90) ($20.70)\n 6/23/2025 30 ($6.96) ($208 80)\n 6/23/2025 75 ($6.94) ($520 50)\n 6/23/2025 200 ($6.88) ($1,376.00)\n 6/23/2025 1350 ($6.85) ($9,247.50)\n 7813 ($53,288.13) 150 $1,043.25 7663 $29,509.45 ($22,735.43)\n\f","ocr_status":2,"date_upload":"2026-05-18T06:05:43.353439-07:00","document_number":"12","attachment_number":3,"pacer_doc_id":"093015216057","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 3. Loss Chart","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479529131/","id":479529131,"tags":[],"absolute_url":"/docket/71033169/12/4/collier-v-altimmune-inc/","date_created":"2026-05-18T06:05:23.486112-07:00","date_modified":"2026-05-22T03:44:08.384630-07:00","sha1":"6c856e867e2b7543273497f9e9f2f58d525eaec9","page_count":26,"file_size":286700,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.12.4.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 1 of 26\n\n\n\n\n Exhibit 4\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 2 of 26\n\n\n\n THE ROSEN LAW FIRM P.A.\n BIOGRAPHY\n\nI. ATTORNEYS\n\nLAURENCE ROSEN \u2013 MANAGING PARTNER\n\n Laurence Rosen is a 1988 graduate of New York University School of Law. He earned an\n\nM.B.A. in finance and accounting at the University of Chicago Graduate School of Business and\n\na B.A. in Economics from Emory University. Mr. Rosen served as a law clerk to the Honorable\n\nStanley S. Brotman, Senior United States District Judge for the District of New Jersey. Mr. Rosen\n\nentered private practice as an associate at the law firm of Skadden Arps Slate Meagher & Flom in\n\nNew York City where he participated in a number of complex securities class action and derivative\n\nlitigation matters. He later served as an associate at McCarter & English in Newark, New Jersey\n\nwhere he specialized in securities and business litigation.\n\n After practicing general securities and commercial litigation in New York City with Solton\n\nRosen & Balakhovsky LLP, Mr. Rosen founded The Rosen Law Firm to represent investors\n\nexclusively in securities class actions and derivative litigation. Mr. Rosen is admitted to practice\n\nlaw in Arizona, California, Florida, New Jersey, and New York. Mr. Rosen is also admitted to\n\npractice before numerous United States District Courts throughout the country and the United\n\nStates Court of Appeals for the Second, Fourth, and Sixth Circuits.\n\n In 2019-2025 Lawdragon named Mr. Rosen as one of the 500 Leading Plaintiff Financial\n\nLawyers. Mr. Rosen was also named by law360 as Titan of Plaintiffs\u2019 Bar for 2020. Mr. Rosen\n\nwas selected to Super Lawyers in 2017-2024.\n\n\n\n\nROSEN LAW FIRM BIOGRAPHY 1\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 3 of 26\n\n\n\nPHILLIP KIM \u2013 PARTNER\n\n Mr. Kim graduated from Villanova University School of Law in 2002. He received a B.A.\n\nin Economics from The Johns Hopkins University in Baltimore, Maryland in 1999. Prior to joining\n\nThe Rosen Law Firm, Mr. Kim served as Assistant Corporation Counsel for the City of New York\n\nin the Special Federal Litigation Division. In that position, Mr. Kim defended a number of class\n\naction lawsuits, litigated numerous individual actions, and participated in more than seven trials.\n\nMr. Kim focuses his practice on securities class actions and shareholder derivative litigation. Mr.\n\nKim is admitted to the bar of the State of New York and admitted to practice in the Southern,\n\nEastern, Northern and Western Districts of New York, the District of Colorado, the Eastern District\n\nof Wisconsin, the Eastern District of Michigan, the Southern District of Texas, and United States\n\nCourt of Appeals for the Second, Sixth and Ninth Circuits.\n\n In 2019-2025 Lawdragon named Mr. Kim as one of the 500 Leading Plaintiff Financial\n\nLawyers. In 2023-2024 Mr. Kim was selected to Super Lawyers. Mr. Kim was recognized by Best\n\nLawyers in The Best Lawyers of America 2024-2026.\n\nJACOB A. GOLDBERG \u2013 PARTNER\n\n Mr. Goldberg is a 1988 graduate of Columbia University. Mr. Goldberg received his J.D.,\n\ncum laude, from the Temple University School of Law in 1992. For over 23 years, Mr. Goldberg\n\nhas litigated complex cases at the highest levels, championing the rights of investors, employees\n\nand consumers. Mr. Goldberg has recovered over $200 million for investors in securities class\n\nactions. In addition to serving in leadership roles in securities class actions, Mr. Goldberg has\n\nlitigated many cases under state corporations laws, against faithless boards of directors both on\n\nbehalf of shareholders, in the mergers and acquisitions context, and, derivatively, on behalf of\n\ncorporations, to remedy harm to the corporation itself. Mr. Goldberg is admitted to practice law\n\nin the Commonwealth of Pennsylvania, New York, the United States Supreme Court, the United\n\nROSEN LAW FIRM BIOGRAPHY 2\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 4 of 26\n\n\n\nStates Court of Appeals for the Second, Third, Fourth and Sixth Circuits, and various United States\n\nDistrict Courts across the country.\n\n In 2019-2025 Lawdragon named Mr. Goldberg as one of the 500 Leading Plaintiff\n\nFinancial Lawyers.\n\nJONATHAN A. SAIDEL \u2013 PARTNER\n\n Mr. Saidel has had a long and distinguished career in Pennsylvania politics, as well as in\n\nthe roles of attorney, accountant and author. He served as Philadelphia city controller for four\n\nconsecutive terms, each time earning reelection by a wide margin, and enacting financial reforms\n\nthat have saved taxpayers upwards of $500 million. Later, in 2010 he went on to campaign for\n\nlieutenant governor of Pennsylvania, where he was runner-up to Scott Conklin by only a few\n\nthousand votes out of almost 1 million cast. A Lifelong resident of Northeast Philadelphia, Mr.\n\nSaidel\u2019s tireless dedication to fiscal discipline reduced the city's tax burden and spurred economic\n\ndevelopment. Mr. Saidel also pushed for important business tax incentives and expanded minority\n\nand small business lending, all of which have revitalized the city, helping it prosper and come back\n\nfrom the brink of bankruptcy in the early 1990's to become one of the most vibrant cities on the\n\nEast Coast.\n\n Mr. Saidel\u2019s book, \"Philadelphia: A New Urban Direction\", is widely considered an\n\nessential guide for effective government and corporate governance and is required reading at many\n\ncolleges and universities.\n\n Mr. Saidel received his JD from the Widener University of Law and is a graduate of Temple\n\nUniversity. He is also an adjunct lecturer at the University of Pennsylvania Fels Institute of\n\nGovernment, and Drexel University's MBA Program. In addition to being a Certified Public\n\nAccount, Jonathan is a recipient of the National Association of Local Government Auditor's\n\nKnighton Award, the President's Council on Integrity and Efficiency Award for Excellence,\n\nROSEN LAW FIRM BIOGRAPHY 3\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 5 of 26\n\n\n\nmultiple special project awards from the National Association of Local Government Auditors, and\n\nthe \"Controller of the Year\" award, a peer recognition presented by the Pennsylvania City\n\nControllers Association.\n\nSARA FUKS \u2013 PARTNER\n\n Ms. Fuks graduated from Fordham University School of Law, cum laude, in February\n\n2005, where she was a member of Fordham Law Review. She received her B.A. in Political\n\nScience, magna cum laude, from New York University in 2001. Ms. Fuks began her practice at\n\nDewey Ballantine, LLP where she focused on general commercial litigation and then went on to\n\nprosecute numerous ERISA and securities class actions as an associate at Milberg LLP. Ms. Fuks\n\nis admitted to the bar of the State of New York and admitted to practice in the United States District\n\nCourts for the Southern District and Eastern District of New York, and the Eastern District of\n\nMichigan. Ms. Fuks was selected to SuperLawyers in 2021-2024 and SuperLawyers Rising Stars\n\nin 2017-2019. In 2025 Lawdragon named Ms. Fuks as one of the 500 Leading Plaintiff Financial\n\nLawyers.\n\nJONATHAN HORNE \u2013 PARTNER\n\n Mr. Horne is a 2009 graduate of New York University School of Law, where he received\n\nthe Lederman/Milbank Law, Economics, and Business fellowship, and holds a B.A. in Economics\n\n& Philosophy from the University of Toronto. Mr. Horne began his practice at Kaye Scholer LLP.\n\nMr. Horne specializes in securities litigation. He is admitted to practice in New York and the\n\nUnited States District Courts for the District of Colorado and the Southern and Eastern Districts\n\nof New York. Mr. Horne was named a Super Lawyer \u2013 Rising Star for the New York Metro Area\n\nevery year since 2015. In 2025 Lawdragon named Mr. Horne as one of the 500 Leading Plaintiff\n\nFinancial Lawyers.\n\n\n\n\nROSEN LAW FIRM BIOGRAPHY 4\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 6 of 26\n\n\n\nYU SHI \u2013 PARTNER\n\n Mr. Shi received his J.D. from Columbia Law School in 2011 and his B.A., cum laude,\n\nfrom Columbia University in 2008. In 2024, Lawdragon recognized Mr. Shi as one of the 500\n\nLeading Plaintiffs Financial Lawyers. In 2022, Law360 named Mr. Shi as one of the nation\u2019s top\n\nsecurities attorneys under the age of 40. He has been selected to Super Lawyers each year since\n\n2018. Mr. Shi began his career as a Special Assistant Corporation Counsel in the New York City\n\nLaw Department\u2019s Economic Development Division. Mr. Shi joined The Rosen Law Firm in 2012\n\nand focuses his practice on securities litigation. He is admitted to practice in the State of New\n\nYork, the United States District Courts for the Eastern District of New York, Southern Districts of\n\nNew York, and the District of Colorado, and the United States Court of Appeals for the Second\n\nCircuit. In 2025 Lawdragon named Mr. Shi as one of the 500 Leading Plaintiff Financial Lawyers.\n\nJONATHAN STERN \u2013 PARTNER\n\n Mr. Stern graduated from New York University School of Law in May of 2008, where he\n\nwas a Development Editor of the Annual Survey of American Law. He received his B.A. in\n\nPhilosophy with Honors from McGill University. Mr. Stern began his practice in the litigation\n\ndepartment of Simpson Thacher & Bartlett LLP, and then went on to practice at the litigation\n\nboutique of Simon & Partners LLP, where he participated in a Federal trial. Mr. Stern is admitted\n\nto the bar of the State of New York and admitted to practice in the United States Southern and\n\nEastern District Courts of New York and the United States Court of Appeals for the Second Circuit.\n\nfor the First, Sixth, Seventh, Eighth and Ninth Circuits, and the United States Supreme Court. In\n\n2024-25 Lawdragon named Mr. Stern as one of the 500 Leading Plaintiff Financial Lawyers.\n\nJING CHEN \u2013 PARTNER\n\n Ms. Chen received a Juris Doctor degree from Pace University School of Law in 2011,\n\nJuris Master degree from China University of Political Science and Law in Beijing, China and\n\nROSEN LAW FIRM BIOGRAPHY 5\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 7 of 26\n\n\n\nB.A. in English Literature and Linguistics from Shandong University in Jinan, China. She is\n\nadmitted to practice in New York, New Jersey, and China. Prior to joining The Rosen Law Firm,\n\nMs. Chen practiced corporate law, commercial transactions and arbitration for over two years. In\n\n2024-25 Lawdragon named Ms. Chen as one of the 500 Leading Plaintiff Financial Lawyers.\n\nBRIAN ALEXANDER \u2013 PARTNER\n\n Mr. Alexander graduated from Harvard Law School, cum laude, in 2008. He\n\nreceived a B.A. from Cornell University, magna cum laude, in 2003. Prior to joining the Rosen\n\nLaw Firm, Mr. Alexander practiced complex commercial litigation at Boies Schiller Flexner LLP\n\nand other prominent law firms in New York. He also served as a law clerk to the Honorable\n\nRaymond J. Dearie of the United States District Court for the Eastern District of New York. He\n\nis admitted to practice in New York, the United States District Courts for the Eastern and Southern\n\nDistricts of New York, and United States Court of Appeals for the Ninth Circuit. Mr. Alexander\n\nwas recognized by Best Lawyers as Best Lawyers: Ones to Watch 2025. In 2025 Lawdragon\n\nnamed Mr. Alexander as one of the 500 Leading Plaintiff Financial Lawyers.\n\nDANIEL TYRE-KARP \u2013 PARTNER\n\n Prior to joining The Rosen Law Firm in May 2018, Mr. Tyre-Karp was a senior associate\n\nin the securities litigation and corporate governance group at Weil, Gotshal & Manges, where he\n\nadvised corporate and individual clients on a variety of high-stakes regulatory and litigation\n\nmatters in state and federal courts. Mr. Tyre-Karp\u2019s extensive experience includes working on\n\nseveral of the largest recent shareholder class action litigations (In re American International\n\nGroup, Inc. 2008 Securities Litigation, Docket No. 08-CV-4772 (S.D.N.Y.) and related opt-out\n\nactions; In re El Paso Corporation Shareholder Litigation, Docket No. 6949 (Del. Ch.)),\n\nparticipating in complex business and bankruptcy litigations (In re Lehman Brothers Holdings,\n\nInc., et al, Docket No. 1:08-bk-13555 (Bankr. S.D.N.Y.), and advising numerous clients facing\n\nROSEN LAW FIRM BIOGRAPHY 6\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 8 of 26\n\n\n\nFINRA and SEC investigations. Mr. Tyre-Karp graduated with honors from Wesleyan University\n\nin 2003 and received his J.D. from New York University School of Law in 2009, where he served\n\nas Senior Notes Editor of the Journal of Legislation and Public Policy. He is admitted to practice\n\nin New York and the United States District Courts for the Southern and Eastern Districts of New\n\nYork. Mr. Tyre-Karp was recognized by Best Lawyers as Best Lawyers: Ones to Watch 2025-\n\n2026. In 2025 Lawdragon named Mr. Tyre-Karp as one of the 500 Leading Plaintiff Financial\n\nLawyers.\n\nROBIN BRONZAFT HOWALD \u2013 COUNSEL\n\n Ms. Howald is a graduate of Stanford Law School where she was a member of the Stanford\n\nLaw Review. Ms. Howald earned her BA from Barnard College, magna cum laude. Ms. Howald\n\njoined the firm in 2021 and focuses her practice on securities litigation. For the last 15 years, Ms.\n\nHowald has prosecuted major securities litigations. She was one of the lead attorneys in cases that\n\nachieved settlements of $250 million for injured investors, including Schleicher v. Wendt, 618 F.3d\n\n679 (7th Cir. 2010) ($41.5 million), In re Mannkind Corp. Securities Litigation (C.D. California)\n\n($23 million); In re ECI Telecom Ltd. Securities Litigation (Eastern District of Virginia) ($21.75\n\nmillion), In re Gilat Satellite Networks, Ltd. Securities Litigation (E.D.N.Y.) ($20 million), In re\n\nMusicmaker.com Securities Litigation, 2001 WL 34062431 (C.D. Cal. 2001) ($13.75 million), In\n\nre Puda Coal Inc. Securities Litigation (S.D.N.Y.) ($8.6 million following reconsideration of grant\n\nof summary judgment), Jenson v. Fiserv Trust Co., 256 F. App\u2019x. 924 (9th Cir. 2007) ($8.5 million\n\nrecovered for victims of a Ponzi scheme). Ms. Howald is admitted to the bars of California, New\n\nYork, the United States District Courts for the Eastern and Southern Districts of New York, the\n\nCentral, Eastern, and Northern Districts of California, the Eastern District of Michigan, and the\n\nUnited States Court of Appeals for the First, Sixth, Seventh, Eighth, and Ninth Circuits.\n\n\n\n\nROSEN LAW FIRM BIOGRAPHY 7\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 9 of 26\n\n\n\nGONEN HAKLAY \u2013 COUNSEL\n\n Mr. Haklay graduated from Stanford University School of Law in 1995. He received a\n\nB.A. in Political Science from The University of Massachusetts at Amherst in 1992. After several\n\nyears as an associate at a large Philadelphia law firm, Mr. Haklay joined the Philadelphia District\n\nAttorney\u2019s office. As a prosecutor, he tried over 100 criminal jury cases and handled both capital\n\nand non-capital homicide cases. After 12 years as prosecutor, Mr. Haklay joined a prominent\n\nplaintiffs\u2019 firm where he tried over ten asbestos cases, recovering millions of dollars for his clients.\n\nAs a young man, Mr. Haklay served as an infantryman in the Israel Defense Forces. Mr. Haklay\n\nis admitted to the bars of the Commonwealth of Pennsylvania, the State of New Jersey, the United\n\nStates District Court for the Eastern District of Pennsylvania, and the United States Third Circuit\n\nCourt of Appeals. Mr. Haklay was recognized by Best Lawyers as Best Lawyers: Ones to Watch\n\n2025-2026.\n\nERICA STONE \u2013 COUNSEL\n\n Ms. Stone graduated from the Benjamin N. Cardozo School of Law in 2013. She received\n\nher B.A. in Political Science and Communications, cum laude, from the University of\n\nPennsylvania in 2009. She is admitted to practice in New York, New Jersey, and the United States\n\nDistrict Courts for the Southern District and Eastern District of New York, the District of New\n\nJersey, the Eastern District of Wisconsin, and the Eastern District of Michigan. In 2024, Ms. Stone\n\nwas selected to Super Lawyers. Ms. Stone was recognized by Best Lawyers as Best Lawyers: Ones\n\nto Watch 2025-2026.\n\nJOSHUA BAKER \u2013 COUNSEL\n\n Mr. Baker graduated from the New York University School of Law in 2013. He received\n\na B.A. from the University of Maryland in 2009. Prior to joining the Rosen Law Firm, Mr. Baker\n\npracticed complex commercial litigation for a New York firm. He is admitted to practice in New\n\nROSEN LAW FIRM BIOGRAPHY 8\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 10 of 26\n\n\n\nYork, Massachusetts, and United States District Courts for the Eastern and Southern Districts of\n\nNew York and the District of Massachusetts. Mr. Baker was recognized by Best Lawyers as Best\n\nLawyers: Ones to Watch 2025-2026.\n\nMICHAEL COHEN \u2013 COUNSEL\n\n Mr. Cohen focuses his practice on securities and shareholder derivative litigation. Prior to\n\njoining The Rosen Law Firm in 2021, Mr. Cohen was an associate in the litigation practice of\n\nKramer Levin Naftalis & Frankel LLP, where he advised corporate and individual clients on a\n\nwide variety of litigation and regulatory matters in federal and state courts. He has also served as\n\na law clerk to the Honorable Corinne Beckwith of the District of Columbia Court of Appeals. Mr.\n\nCohen is admitted to practice in New York and the United States District Courts for the Eastern\n\nand Southern Districts of New York. Mr. Cohen was recognized by Best Lawyers as Best Lawyers:\n\nOnes to Watch 2023-2026. In 2025, Mr. Cohen was recognized by ALM Law.com Elite Trial\n\nLawyers, Rising Star of the Plaintiffs Bar.\n\nLEAH HEIFETZ-LI \u2013 COUNSEL\n\n Ms. Heifetz-Li is a 2009 graduate of Columbia Law School, and received a B.A. from the\n\nUniversity of Pennsylvania. Ms. Heifetz-Li served as a Law Clerk to the Honorable Cynthia S.\n\nKern, New York State Supreme Court, New York County. She has extensive experience in class\n\naction litigation, having previously practiced at a large class action firm representing shareholders\n\nin merger and acquisition litigation as well as shareholder derivative actions. Ms. Heifetz-Li has\n\nworked on case teams that secured significant financial recoveries for stockholders as well as\n\ncorporate governance reforms in the Delaware Court of Chancery and other courts throughout the\n\ncountry. Ms. Heifetz-Li was recognized by Best Lawyers as Best Lawyers: Ones to Watch 2026.\n\n\n\n\nROSEN LAW FIRM BIOGRAPHY 9\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 11 of 26\n\n\n\nERIC JUN BI \u2013 ATTORNEY\n\n Mr. Bi is a 2024 graduate of Cornell Law School. He earned his Bachelor of Laws from\n\nYanching Institute of Technology in 2020. Mr. Bi is fluent in Mandarin. Mr. Bi is admitted to\n\npractice in New York and Pennsylvania.\n\nHENRY BLOXENHEIM \u2013 ATTORNEY\n\n Mr. Bloxenheim graduated from Columbia Law School in 2023. Mr. Bloxenheim received\n\nhis B.A. in Political Science, summa cum laude, from Brooklyn College. Mr. Bloxenheim is\n\nadmitted to practice in New York and in the United States District Courts for the Southern District\n\nand Eastern District of New York.\n\nCHRISTIE BUZZETTI \u2013 ATTORNEY\n\n Ms. Buzzetti graduated from Brooklyn Law School in 2022. She received her B.A. in\n\nPolitical Science from the University of California, Los Angeles in 2016. Ms. Buzzetti is admitted\n\nto practice in New York and in the United States District Courts for the Eastern and Southern\n\nDistrict of New York. Ms. Buzzetti was recognized by Best Lawyers as Best Lawyers: Ones to\n\nWatch 2026.\n\nJOSHUA CLEVELAND \u2013 ATTORNEY\n\n Mr. Cleveland graduated from Rutgers Law School in 2024, where he served as State\n\nConstitutional Law Editor of the Rutgers University Law Review. After law school, he clerked for\n\nthe Honorable Michael J. Kassel in Camden County, New Jersey, assisting on matters involving\n\ncomplex civil litigation. Before pursuing law, Joshua worked as a financial analyst for a global\n\nhealthcare information technology company. He draws on this background to advise and represent\n\nclients in breach of fiduciary duty and shareholder derivative litigation. Joshua is admitted to\n\npractice in Pennsylvania. He holds a B.A. in Economics from Villanova University, with additional\n\nstudy at the London School of Economics.\n\nROSEN LAW FIRM BIOGRAPHY 10\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 12 of 26\n\n\n\nYITZCHOK (IZZY) FISHBACH \u2013 ATTORNEY\n\n Mr. Fishbach received his J.D. from Vanderbilt University Law School in 2022, where he\n\nserved as the Articles Editor of the Environmental Law and Policy Annual Review. He received\n\nhis B.A. in Political Science from Binghamton University in 2019. Mr. Fishbach is admitted to\n\npractice in New York, Tennessee, and the United States District Courts for the Eastern and\n\nSouthern Districts of New York.\n\nLUKE FOLEY \u2013 ATTORNEY\n\n Mr. Foley received his J.D. from the William and Mary Law School in 2022. He received\n\nhis B.A. in History and Citizenship & Civic Engagement from Syracuse University in 2016. Prior\n\nto joining the Rosen Law Firm in September 2023, Mr. Foley was the Law Clerk to the Hon.\n\nBarbara Buono Stanton of the New Jersey Superior Court, Passaic County. Mr. Foley is admitted\n\nto practice in Maryland.\n\nRYAN HEDRICK \u2013 ATTORNEY\n\n Mr. Hedrick received his J.D. from the University of Chicago in 2019. He received his\n\nB.A. in Linguistics and Political Science, summa cum laude, from The Ohio State University in\n\n2015. Mr. Hedrick joined the Rosen Law Firm in August 2019. Mr. Hedrick is admitted to practice\n\nin New York, New Jersey, the United States District Courts for the Eastern and Southern Districts\n\nof New York, the District of New Jersey, the District of Colorado, and United States Court of\n\nAppeals for the Ninth Circuit. Mr. Hedrick was recognized by Best Lawyers as Best Lawyers:\n\nOnes to Watch 2026.\n\nHA SUNG (SCOTT) KIM \u2013 ATTORNEY\n\n Mr. Kim received his J.D. from the Columbia Law School in 2017. He received his B.A.,\n\nmagna cum laude, from Wheaton College in 2013. Mr. Kim joined the Rosen Law Firm in January\n\n\n\n\nROSEN LAW FIRM BIOGRAPHY 11\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 13 of 26\n\n\n\n2020. Mr. Kim is admitted to practice in New York. Mr. Kim was recognized by Best Lawyers as\n\nBest Lawyers: Ones to Watch 2026.\n\nIAN MCDOWELL \u2013 ATTORNEY\n\n Mr. McDowell graduated cum laude from the University of Richmond School of Law in\n\n2022. He received his B.A. from James Madison University in 2016. Mr. McDowell is admitted\n\nto practice in Pennsylvania and Maryland as well as the United States District Court for the Eastern\n\nDistrict of Pennsylvania. Mr. McDowell was recognized by Best Lawyers as Best Lawyers: Ones\n\nto Watch 2026.\n\nCATHERINE O\u2019SULLIVAN \u2013 ATTORNEY\n\n Ms. O'Sullivan graduated from the University of Denver Sturm College of Law in 2024,\n\nwhere she was an Articles Editor of the Denver Law Review. After law school, she clerked for\n\nJustice Brian D. Boatright of the Colorado Supreme Court. She serves as a mentor for the nonprofit\n\norganization \"Law School...Yes We Can!\" She holds a B.A. in Philosophy from Boston College.\n\nMs. O'Sullivan is admitted to practice in Pennsylvania and Colorado.\n\nOLIVIA SIMKINS \u2013 ATTORNEY\n\n Ms. Simkins is a 2024 graduate of Tulane University School of Law. She earned her B.A.\n\nin Linguistics and English cum laude from Tulane University in 2017. Ms. Simkins is admitted to\n\npractice in Pennsylvania and the United States District Court for the Eastern District of\n\nPennsylvania.\n\nII. RECENT ACCOMPLISHMENTS OF THE ROSEN LAW FIRM, P.A.\n\n \u2022 Alibaba Group Holding Ltd., (S.D.N.Y.). Rosen Lead Counsel. $250 million.\n\n \u2022 Fiat Chrysler Automobiles, (S.D.N.Y.). Rosen Co-Lead Counsel. $110 million.\n\n \u2022 Infinity Q Diversified Alpha Fund, (N.Y. Supreme). Rosen Co-Lead Counsel. $48\n\n million.\n\nROSEN LAW FIRM BIOGRAPHY 12\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 14 of 26\n\n\n\n \u2022 Silver Wheaton Corp., (C.D. Cal.). Rosen Lead Counsel. $41.5 million.\n\n \u2022 Omega Healthcare Investors, Inc., (S.D.N.Y.). Rosen Lead Counsel. $30.75 million.\n\n \u2022 Magnachip Semiconductor Corp., (N.D. Cal.). Rosen Co-Lead Counsel. $29.7 million.\n\n \u2022 Och-Ziff Capital Management Group LLC, (S.D.N.Y.). Rosen Co-Lead Counsel.\n\n $28.75 million.\n\n \u2022 Vanguard Target Date Retirement Funds, (E.D. Pa.). Rosen Lead Counsel. $25\n\n million.\n\n \u2022 Walter Investment Management, (S.D. Fla.). Rosen Co-Lead Counsel. $24 million.\n\n \u2022 Galena Biopharma, Inc., (D. Or.). Rosen Co-Lead Counsel. $20.165 million.\n\n \u2022 Live Nation Entertainment, Inc., (C.D. Cal.). Rosen Co-Lead Counsel. $20 million.\n\n \u2022 El Pollo Loco Holdings, Inc., (C.D. Cal.). Rosen Co-Lead Counsel. $20 million.\n\n \u2022 Tibet Pharmaceuticals, Inc., (D.N.J.). Rosen Lead Counsel. $14 million bankruptcy\n\n settlement. $2.075 million with auditor.\n\n \u2022 USA Technologies, Inc., (E.D. Pa.). Rosen Lead Counsel. $15.3 million.\n\n \u2022 Zillow Group, Inc. Sec. Litig., (W.D. Wash.). Rosen Lead Counsel. $15 million.\n\n \u2022 Silvercorp Metals, Inc., (S.D.N.Y.). Rosen Plaintiffs\u2019 Counsel. $14 million.\n\n \u2022 Sandridge Energy, Inc., (W.D. Okla.). Rosen Co-Lead Counsel. $13.945 million.\n\n \u2022 Astec Industries, Inc., (E.D. Tenn.). Rosen Lead Counsel. $13.7 million.\n\n \u2022 Blue Apron Holdings, Inc., (E.D.N.Y.). Rosen Co-Lead Counsel. $13.25 million.\n\n \u2022 Canopy Growth Corporation, (D.N.J.). Rosen Co-Lead Counsel. $13 million.\n\n \u2022 SeaWorld Entertainment Inc. (Shareholder Derivative) (Del. Ch.). Rosen Co-Lead\n\n Counsel. $12.5 million.\n\n \u2022 The RealReal, Inc., (N.D. Cal.). Rosen Lead Counsel. $11 million.\n\n\nROSEN LAW FIRM BIOGRAPHY 13\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 15 of 26\n\n\n\n \u2022 Full Truck Alliance Co. (E.D.N.Y.) and (NY. Sup.). Rosen Federal Lead Counsel. $10.25\n\n million.\n\n \u2022 Quest Energy Partners LP, (W.D. Okla.). Rosen Lead Counsel. $10.1 million all classes.\n\n \u2022 Prosper Marketplace, Inc., (Cal. Superior). Rosen Class Counsel. $10 million.\n\n \u2022 PG&E Corp., (N.D. Cal.). Rosen Co-Lead Counsel. $10 million.\n\n \u2022 Textainer Financial Servs. Corp., (Cal. Superior). Rosen Co-Lead Counsel. $10 million.\n\n \u2022 comScore, Inc. (Shareholder Derivative), Rosen Co-Lead Counsel. $10 million.\n\n \u2022 Santander Consumer USA Holdings Inc., (N.D. Tex.). Rosen Co-Lead Counsel. $9.5\n\n million.\n\n \u2022 Uxin Limited, (E.D.N.Y.). Rosen Lead Counsel. $9.5 million.\n\n \u2022 Concordia International Corp., (S.D.N.Y.). Rosen Lead Counsel. $9.25 million.\n\n \u2022 PPDAI Group Inc., (E.D.N.Y.). Rosen Lead Counsel. $9 million.\n\n \u2022 Puda Coal, (S.D.N.Y.). Rosen Co-Lead Counsel. $8.7 million.\n\n \u2022 RINO International Corporation, (C.D. Cal.). Rosen Lead Counsel. $8,685,000.\n\n \u2022 Acer Therapeutics, Inc., (S.D.N.Y.). Rosen Lead Counsel. $8.35 million.\n\n \u2022 Montage Technology Group Limited, (N.D. Cal.). Rosen Lead Counsel. $7.25 million.\n\n \u2022 AgFeed Industries, (M.D. Tenn.). Rosen Lead Counsel. $7 million.\n\n \u2022 Sundial Growers, Inc., (S.D.N.Y.). Rosen Co-Lead Counsel. $7 million.\n\n \u2022 Akazoo S.A., (E.D.N.Y.). Rosen Co-Lead Counsel. $6.51 million.\n\n \u2022 Global Brokerage, Inc. f/k/a FXCM, Inc. Sec. Litig., (S.D.N.Y.). Rosen Lead Counsel.\n\n $6.5 million.\n\n \u2022 Aeterna Zentaris, Inc., (D. N.J.). Rosen Class Counsel. $6.5 million.\n\n \u2022 Bender v. Vertex Energy, Inc., (S.D. Tex.). Rosen Lead Counsel. $6.3 million.\n\n\nROSEN LAW FIRM BIOGRAPHY 14\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 16 of 26\n\n\n\n \u2022 Sunlands Technology Group, (E.D.N.Y.). Rosen Lead Counsel. $6.2 million.\n\n \u2022 Covia Holdings Corp., (N.D. Ohio). Rosen Lead Counsel. $6 million.\n\n \u2022 FalconStor Software, Inc., (E.D.N.Y.). Rosen Lead Counsel. $5 million.\n\n \u2022 Jumia Technologies AG, (S.D.N.Y.). Rosen Lead Counsel. $5 million.\n\n \u2022 Momo, Inc., (S.D.N.Y.). Rosen Lead Counsel. $5 million.\n\n \u2022 SOS Limited, (D.N.J.). Rosen Co-Lead Counsel. $5 million.\n\n \u2022 Missfresh Limited, (S.D.N.Y.). Rosen Co-Lead Counsel. $4.9039 million.\n\n \u2022 Compass Minerals International, (D. Kansas). Rosen Lead Counsel, $4.9 million,\n\n pending Court approval.\n\n \u2022 State Street, (D. Mass.). Rosen Lead Counsel. $4.9 million.\n\n \u2022 Dada Nexus Limited, (C.D. Cal.). Rosen Lead Counsel. $4.8 million.\n\n \u2022 Stronghold Digital Mining, Inc., (S.D.N.Y.) Rosen Lead Counsel. $4.75 million and 25\n\n Bitcoins.\n\n \u2022 Altice USA Inc., (E.D.N.Y.). Rosen Lead Counsel. $4.75 million.\n\n \u2022 KIOR, Inc., (S.D. Tex.). Rosen Co-Lead Counsel. $4.5 million.\n\n \u2022 Entropin, Inc., (C.D. Cal.). Rosen Lead Counsel. $4.5 million.\n\n \u2022 Sonus Networks, Inc., (D. Mass). Rosen Co-Lead Counsel. $4.5 million.\n\n \u2022 Uni-Pixel, Inc., (S.D. Tex.). Rosen Co-Lead Counsel. $4.5 million.\n\n \u2022 China Expert Technology, Inc., (S.D.N.Y.). Rosen Lead Counsel. $4.2 million.\n\n \u2022 IDreamSky Technology Limited, (S.D.N.Y.). Rosen Co-Lead Counsel. $4.15 million.\n\n \u2022 Universal Travel Group, Inc., (D.N.J.). Rosen Lead Counsel. $4.075 million.\n\n \u2022 Allegiant Travel Co., (D. Nev.). Rosen Lead Counsel. $4 million.\n\n \u2022 Zynerba Pharms., Inc., (E.D. Pa.). Rosen Co-Lead Counsel. $4 million.\n\n\nROSEN LAW FIRM BIOGRAPHY 15\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 17 of 26\n\n\n\n \u2022 Dapper Labs, Inc., (S.D.N.Y.). Rosen Lead Counsel, $4 million.\n\n \u2022 Liberty Oilfield Services, Inc., (D. Colo.). Rosen Lead Counsel. $3.9 million.\n\n \u2022 Caribou Biosciences, Inc., (N.D. Cal.). Rosen Co-Lead Counsel. $3.9 million.\n\n \u2022 China Electric Motor, Inc., (C.D. Cal.). Rosen Lead Counsel. $3,778,333.33.\n\n \u2022 IsoRay, Inc., (E.D. Wash.). Rosen Co-Lead Counsel. $3,537,500.\n\n \u2022 Deer Consumer Products, Inc., (C.D. Cal.). Rosen Lead Counsel. $3.55 million.\n\n \u2022 SAExploration Holdings, Inc., (S.D. Tex.). $3.55 million.\n\n \u2022 L&L Energy, Inc., (S.D.N.Y.). Rosen Lead Counsel. $3.5 million.\n\n \u2022 Tarena International, Inc., N (E.D.N.Y.). Rosen Lead Counsel. $3.5 million.\n\n \u2022 Catalyst Pharmaceutical Partners, Inc., (S.D. Fla.). Rosen Lead Counsel. $3.5 million.\n\n \u2022 Sunlight Financial Holdings, Inc., (S.D.N.Y.). Rosen Lead Counsel. $3.5 million.\n\n \u2022 Keyuan Petrochemicals, Inc. and Auditor, (S.D.N.Y.) & (D.N.J.). Rosen Lead Counsel.\n\n $3.5 million.\n\n \u2022 StockerYale, Inc., (D.N.H.). Rosen Lead Counsel. $3.4 million.\n\n \u2022 Industrial Enterprises of America, Inc., (S.D.N.Y.). Rosen Co-Lead Counsel. $3.4\n\n million.\n\n \u2022 Ampio Pharmaceuticals, Inc., (C.D. Cal.). Rosen Lead Counsel. $3.4 million.\n\n \u2022 Textura Corporation, (N.D Ill.). Rosen Lead Counsel. $3.3 million.\n\n \u2022 Roka Bioscience, Inc., (D.N.J.). Rosen Lead Counsel. $3.275 million.\n\n \u2022 Intrusion, Inc., (E.D. Tex.). Rosen Lead Counsel. $3.25 million.\n\n \u2022 Wedbush Morgan Securities, Inc., (Cal. Superior). Co-Lead Counsel. $3.2 million.\n\n \u2022 New Oriental Education & Technology Group Inc., (D.N.J.). Rosen Co-Lead Counsel.\n\n $3.15 million.\n\n\nROSEN LAW FIRM BIOGRAPHY 16\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 18 of 26\n\n\n\n \u2022 TierOne Corporation, (D. Neb.). Rosen Lead Counsel. $3.1 million.\n\n \u2022 GDS Holdings Limited, (C.D. Cal.). Rosen Lead Counsel. $3 million.\n\n \u2022 Hanmi Financial Corporation, (C.D. Cal.). Rosen Lead Counsel. $3 million.\n\n \u2022 Cadiz, Inc., (C.D. Cal.). Rosen Co-Lead Counsel. $3 million.\n\n \u2022 Fat Brands, Inc., (C.D. Cal.). Rosen Lead Counsel. $3 million.\n\n \u2022 China Finance Online Co. Limited, (S.D.N.Y.). Rosen Lead Counsel. $3 million.\n\n \u2022 Skilled Healthcare Group, Inc., (C.D. Cal.). Rosen Co-Lead Counsel. $3 million.\n\n \u2022 Spectrum Pharms. Inc., (D. Nev.). Rosen Lead Counsel. $2.995 million.\n\n \u2022 MiMedx Group, Inc., (N.D. Ga.). Rosen Lead Counsel. $2.979 million.\n\n \u2022 Pegasus Communications Corp, (E.D. Pa.). Rosen Lead Counsel. $2.95 million.\n\n \u2022 Albany Molecular Research, (E.D.N.Y.). Rosen Lead Counsel. $2.868 million.\n\n \u2022 Lihua International, Inc., (S.D.N.Y.). Rosen Lead Counsel. $2.865 million.\n\n \u2022 TVIA, Inc., (N.D. Cal.). Rosen Lead Counsel. $2.85 million.\n\n \u2022 New Source Energy Partners LP, (S.D.N.Y.). Rosen Lead Counsel. $2.85 million.\n\n \u2022 Innocoll Holdings Public Ltd., (E.D. Pa.). Rosen Lead Counsel. $2.755 million.\n\n \u2022 GigaCloud Technology Inc., (S.D.N.Y.) $2.75 million, pending Court approval.\n\n \u2022 Natural Health Trends Corp., et al., (N.D. Tex.). Rosen Lead Counsel. $2.75 million.\n\n \u2022 Sequans Communications, (E.D.N.Y.). Rosen Co-Lead Counsel. $2.75 million.\n\n \u2022 Akari Therapeutics PLC, (S.D.N.Y.). Rosen Lead Counsel. $2.7 million.\n\n \u2022 Electric Last Mile Solutions, (D.N.J.). Rosen Lead Counsel. $2.7 million.\n\n \u2022 Growlife, Inc., (C.D. Cal.). Rosen Lead Counsel. $2.7 million (cash and stock).\n\n \u2022 Tangoe, Inc., (D. Conn.). Rosen Co-Lead Counsel. $2.55 million.\n\n\n\n\nROSEN LAW FIRM BIOGRAPHY 17\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 19 of 26\n\n\n\n \u2022 Blue Ridge Bankshares, Inc., (E.D.N.Y.). Rosen Lead Counsel. $2.5 million, pending\n\n Court approval.\n\n \u2022 Twitter, Inc., (Cal. Superior). Rosen Co-Lead Counsel. $2.5 million.\n\n \u2022 Radient Pharmaceuticals Corporation, (C.D. Cal.). Rosen Lead Counsel. $2.5 million.\n\n \u2022 Robert T. Harvey Securities Litigation, (C.D. Cal.). Rosen Co-Lead Counsel. $2.485\n\n million.\n\n \u2022 China Education Alliance, Inc., (C.D. Cal.). Rosen Lead Counsel. $2.425 million.\n\n \u2022 Oasmia Pharmaceuticals AB., (E.D.N.Y.). Rosen Co-Lead Counsel. $2.35 million.\n\n \u2022 Capstone Green Energy Corp., (C.D. Cal.). Rosen Co-Lead Cousnel. $2.25 million,\n\n pending Court approval.\n\n \u2022 BioAmber, Inc., (E.D.N.Y.). Rosen Co-Lead Counsel. $2.25 million.\n\n \u2022 DouYu International Holdings Ltd., (D.N.J.). Rosen Co-Lead Counsel. $2.25 million,\n\n pending Court approval.\n\n \u2022 NetApp, Inc., (N.D. Cal.). Rosen Lead Counsel. $2.25 million.\n\n \u2022 Akers Biosciences, Inc., (D.N.J.). Rosen Lead Counsel. $2.25 million.\n\n \u2022 Kanzhun Limited, (D.N.J.). Rosen Lead Counsel. $2.25 million.\n\n \u2022 SkyPeople Fruit Juice, (S.D.N.Y.). Rosen Lead Counsel. $2.2 million.\n\n \u2022 Caesarstone Sdot-Yam Ltd., (S.D.N.Y.). Rosen Co-Lead Counsel. $2.2 million.\n\n \u2022 RCI Hospitality Holdings Inc., (S.D. Tex.). Rosen Co-Lead Counsel. $2.2 million.\n\n \u2022 Fuwei Films, (S.D.N.Y.). Rosen Lead Counsel. $2.15 million.\n\n \u2022 Gulf Resources, Inc., (C.D. Cal.). Rosen Lead Counsel. $2.125 million.\n\n \u2022 PTC Inc., (D. Mass.). Rosen Lead Counsel. $2.1 million.\n\n \u2022 DS Healthcare Group, Inc., (S.D. Fla.). Rosen Lead Counsel. $2.1 million.\n\n\nROSEN LAW FIRM BIOGRAPHY 18\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 20 of 26\n\n\n\n \u2022 Indivior PLC, (D.N.J.). Rosen Lead Counsel. $2 million.\n\n \u2022 Orient Paper, Inc., (C.D. Cal.). Rosen Lead Counsel. $2 million.\n\n \u2022 Mesoblast Limited, (S.D.N.Y.). Rosen Lead Counsel. $2 million.\n\n \u2022 GTT Communications, Inc., (C.D. Cal.). Rosen Lead Counsel. $2 million.\n\n \u2022 EHang Holdings Limited. (C.D. Cal.). Rosen Lead Counsel, $1,985,000, pending Court\n\n approval.\n\n \u2022 Latch, Inc., (S.D.N.Y.). Rosen Lead Counsel. $1.95 million.\n\n \u2022 iBio, Inc., (D. Del.). Rosen Lead Counsel. $1.875 million.\n\n \u2022 CD Projekt SA, No. CV-20-11627 (FMO)(RAOx) (C.D. Cal.). $1.85 million.\n\n \u2022 Ignite Restaurant Group, Inc., (S.D. Tex.). Rosen Lead Counsel. $1.8 million.\n\n \u2022 Electronic Game Card, Inc., (C.D. Cal.). Rosen Lead Counsel. $1.755 million.\n\n \u2022 BMW AG, (D.N.J.). Rosen Lead Counsel. $1.75 million.\n\n \u2022 Natural Health Trends Corp., (C.D. Cal.). Rosen Co-Lead Counsel. $1.75 million.\n\n \u2022 Flux Power Holdings, Inc., (S.D. Cal.). Rosen Lead Counsel. $1.75 million, pending\n\n Court approval.\n\n \u2022 Corrrevio Pharma Corp.,(S.D.N.Y.). Rosen Co-Lead Counsel. $1.75 million.\n\n \u2022 Delstaff LLC (Merger Litigation), (Cal. Superior). $1.6425 million.\n\n \u2022 Worldwide Energy & Manufacturing USA, Inc, (Cal. Superior). Rosen Lead Counsel.\n\n $1.615 million.\n\n \u2022 Alliance MMA, Inc., (D.N.J.). Rosen Lead Counsel. $1.55 million.\n\n \u2022 Lightinthebox Holding Co., Ltd., (S.D.N.Y.). Rosen Lead Counsel. $1.55 million.\n\n \u2022 Nutracea, Inc., (D. Ariz.). Rosen Lead Counsel. $1.5 million.\n\n \u2022 Kraton Corporation, (S.D. Tex.). Rosen Lead Counsel. $1.5 million.\n\n\nROSEN LAW FIRM BIOGRAPHY 19\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 21 of 26\n\n\n\n \u2022 RMG Networks Holding Corporation (Merger Litigation), (Del. Ch.). $1.5 million.\n\n \u2022 BlueNRGY Group Ltd, f/k/a CBD Energy Ltd., (S.D. Tex.). Rosen Lead Counsel. $1.5\n\n million.\n\n \u2022 Ambow Education Holding Ltd., (C.D. Cal.). Rosen Lead Counsel. $1.5 million.\n\n \u2022 Active Power, Inc., (W.D. Tex.). Rosen Lead Counsel. $1.5 million.\n\n \u2022 Northfield Laboratories, Inc., (N.D. Ill.). Rosen Lead Counsel. $1.5 million.\n\n \u2022 PartsBase.com, Inc., (S.D. Fla.). Rosen Lead Counsel. $1.5 million.\n\n \u2022 China Natural Gas, Inc., (D. Del.). Rosen Lead Counsel. $1.5 million.\n\n \u2022 FAB Universal Corp., (S.D.N.Y.). Rosen Co-Lead Counsel. $1.5 million.\n\n \u2022 Sogou, Inc., (S.D.N.Y.). Rosen Co-Lead Counsel. $1.45 million.\n\n \u2022 Code Rebel Corp., (S.D.N.Y.). Rosen Co-Lead Counsel. $1.415 million.\n\n \u2022 Empyrean Bioscience, (N.D. Ga.). Rosen Lead Counsel. $1.4 million.\n\n \u2022 Shattuck Labs, Inc., (E.D.N.Y.). Rosen Lead Counsel. $1.4 million.\n\n \u2022 Longeveron, Inc., (S.D. Fla.). Rosen Lead Counsel. $1.395 million.\n\n \u2022 Agria, Inc., (D.N.J.). Rosen Lead Counsel. $1.3 million.\n\n \u2022 Aterian, Inc., (S.D.N.Y.). Rosen Lead Counsel. $1.3 million.\n\n \u2022 CoCrystal Pharma, Inc., (D.N.J.). Rosen Lead Counsel. $1.265 million.\n\n \u2022 Wins Financial Holdings, Inc., (C.D. Cal.). Rosen Lead Counsel. $1.26 million, pending\n\n Court approval.\n\n \u2022 ERBA Diagnostics, Inc., (S.D. Fla.). Rosen Lead Counsel. $1.215 million.\n\n \u2022 Yingli Green Energy Holding Co. Ltd., (C.D. Cal.). Rosen Lead Counsel. $1.2 million.\n\n \u2022 Himax Technologies, Inc., (C.D. Cal.). Rosen Co-Lead Counsel. $1.2 million.\n\n \u2022 Flight Safety Technologies, Inc., (D. Conn.). Rosen Lead Counsel. $1.2 million.\n\n\nROSEN LAW FIRM BIOGRAPHY 20\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 22 of 26\n\n\n\n \u2022 M.H. Meyerson & Co., (D.N.J.). Rosen Lead Counsel. $1.2 million.\n\n \u2022 Izea, Inc., (C.D. Cal.). Rosen Co-Lead Counsel. $1.2 million.\n\n \u2022 Hywin Holdings Ltd. (N.Y. Supreme). Rosen Lead Counsel. $1 million.\n\n \u2022 India Globalization Capital, Inc., (D. Md.). Rosen Co-Lead Counsel. $1 million.\n\n \u2022 National Lampoon, Inc., (C.D. Cal.). Rosen Lead Counsel. $1 million.\n\n \u2022 Lentuo International, Inc., (C.D. Cal.). Rosen Lead Counsel. $1 million.\n\n \u2022 Katanga Mining Limited, (D.N.J.). Rosen Lead Counsel. $1 million.\n\n \u2022 Busybox.com, Inc., (Cal. Superior). Rosen Co-Lead Counsel. $1 million.\n\nIII. SECURITIES CLASS ACTIONS IN WHICH THE ROSEN LAW FIRM, P.A. IS CURRENTLY\nLEAD COUNSEL\n\n In re Maiden Holdings, Ltd. Securities Litigation, No. 19-CV-5296-RMB-JS (D.N.J.)\n\nRosen Co-Lead Counsel.\n\n In re ChinaCast Education Corporation Sec. Litig., No. CV 12-4621- JFW (PLAx) (C.D.\n\nCal.). Rosen Co-Lead Counsel.\n\n Kasillingam v. Tilray, Inc., No. 20-CV-3459 (PAC) (S.D.N.Y.). Rosen Lead Counsel.\n\n In re NIO, Inc. Securities Litigation, No. 19-CV-1424 (NGG) (JRC) (E.D.N.Y.). Rosen\n\nClass Counsel.\n\n Lavin v. Virgin Galactic Holdings Inc., No. 21-CV-3070 (ARR)(TAM) (E.D.N.Y.). Rosen\n\nLead Counsel.\n\n Handal v. Tenet Fintech Group, Inc., No. 21-cv-6461 (PKC)(RLM) (E.D.N.Y.). Rosen\n\nLead Counsel.\n\n Hoang v. ContextLogic, Inc., No. 21-cv-3930-BLF (N.D. Cal.). Rosen Co-Lead Counsel.\n\n Mallozzi v. Innovative Industrial Properties, Inc., No. 22-cv-2359-EP-JRA (D.N.J.).\n\nRosen Lead Counsel.\n\n\nROSEN LAW FIRM BIOGRAPHY 21\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 23 of 26\n\n\n\n Gru v. Axsome Therapeutics, Inc., No. 22-cv-3925 (AGS) (S.D.N.Y.). Rosen Co-Lead\n\nCounsel.\n\n Farhar v. Ontrak, Inc., No. 21-CV-1987-FLA-A (C.D. Cal.). Rosen Lead Counsel.\n\n Sanchez v. Arrival SA, No. 220cv0172 (DG)(RLM) (E.D.N.Y.). Rosen Lead Counsel.\n\n In re VEON Ltd. Sec. Litig., No. 15-cv-8672 (ALC)(OTW) (S.D.N.Y.). Rosen Lead\n\nCounsel.\n\n In re Volkswagen AG Sec. Litig., No. 22-cv-45-RDA-TCB (E.D. Va.). Rosen Lead\n\nCounsel.\n\n In re DiDi Global Inc. Sec. Litig., No. 21-CV-5807 (LAK) (S.D.N.Y). Rosen Lead\n\nCounsel.\n\n Patterson v. TerraForm Labs Pte Ltd., No. 22-cv-3600-TLT (N.D. Cal.). Rosen Lead\n\nCounsel.\n\n Diaz v. The Gap, Inc., No. 22-cv-7371 (DG)(RER) (E.D.N.Y.). Rosen Lead Counsel.\n\n Armbruster v. Gaia, Inc., No. 22-CV-3267 (D. Colo.). Rosen Lead Counsel.\n\n Pang v. Levitt (Core Scientific, Inc.), No. 22-CV-1191-LY (W.D. Tex.). Rosen Lead\n\nCounsel.\n\n Goodman v. Wheels Up Experience, Inc., No. 23-cv-2900 (OEM)(VMS) (E.D.N.Y.).\n\nRosen Lead Counsel.\n\n In re Enovix Corp. Sec. Litig., No. 23-cv-71-SI (N.D. Cal.). Rosen Co-Lead Counsel.\n\n Gambrill v. CS Disco, Inc., No. 23-cv-8270 (LAK)(SN) (S.D.N.Y.). Rosen Lead Counsel.\n\n Lewandowski v. Tal Education Group, No. 23-cv-1769 (MEF) (JRA) (D.N.J.). Rosen Lead\n\nCounsel.\n\n HRSA-ILA Funds v. adidas AG, No. 23-CV-629-IM (D. Or.). Rosen Lead Counsel.\n\n\n\n\nROSEN LAW FIRM BIOGRAPHY 22\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 24 of 26\n\n\n\n Tan v. PacWest Bancorp., No. CV-23-1685 (JWH)(ADSx) (C.D. Cal.). Rosen Co-Lead\n\nCounsel.\n\n Maschhoff v. Polished.com, No. 22-cv-6605(NGG)(VMS) (E.D.N.Y.). Rosen Lead\n\nCounsel.\n\n Pelham v. VBIT Tech. Corp., No. 23-CV-162-CFC-SRF (D. Del.). Rosen Lead Counsel.\n\n Sporn v. Brainstorm Cell Therapeutics, Inc., No. 23-cv-9630 (DEH) (S.D.N.Y.) Rosen\n\nLead Counsel.\n\n Schelling v. Microvast Holdings, Inc., No. 23-cv-4565 (S.D. Tex.). Rosen Co-Lead\n\nCounsel.\n\n Jaar v. Northern Genesis Acquisition Corp., No. 24-cv-2155 (JLR) (S.D.N.Y.). Rosen Lead\n\nCounsel.\n\n Taylor v. The Chemours Company, No. 24-cv-361-RGA (D. Del.). Rosen Lead Counsel.\n\n Nowakowski v. AXT, Inc., No. 24-cv-2778-MMC (N.D. Cal.). Rosen Lead Counsel.\n\n Dorin v. Exscientia PLC, No. 24-cv-5692-RMD-AMD (D.N.J.). Rosen Lead Counsel.\n\n In re Intel Corp. Sec. Litig., No. 24-cv-2683-TLT (N.D. Cal.). Rosen Co-Lead Counsel.\n\n Yarborough v. Ardelyx, Inc., No. 24-cv-12119-LTS (D. Mass.). Rosen Lead Counsel.\n\n In re Avis Budget Group Inc., Sec. Litig., No. 2:25-cv-03332-MEF-CLW (D.N.J.). Rosen\n\nCo-Lead Counsel.\n\n Nelson v. Sun Communities, Inc., No. 24-cv-13314-MAG (E.D. Mich.). Rosen Lead\n\nCounsel.\n\n Schweiger v. Ultra Clean Holdings, Inc., No. 3:25-cv-2768-JSC (N.D. Cal.). Rosen Lead\n\nCounsel.\n\n Liberato v. Grocery Outlet Holding Corp., No. 4:25-cv-957-JST (N.D. Cal.). Rosen Lead\n\nCounsel.\n\nROSEN LAW FIRM BIOGRAPHY 23\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 25 of 26\n\n\n\n Drott v. Sana Biotechnology, Inc., No. 2:25-cv-512-BJR (W.D. Wash.). Rosen Co-Lead\n\nCounsel.\n\n Evangelista v. Late Stage Asset Management, LLC, No. 1:24-cv-5292 (KAM) (MMH)\n\n(E.D.N.Y.). Rosen Lead Counsel.\n\n Alvarez v. Pacira Biosciences, Inc., No. 2:25-cv-322-SRC-CLW (D.N.J.). Rosen Lead\n\nCounsel.\n\n Lucid Alternative Fund LP v. Elastic N.V., No. 25-cv-785 (RPK)(SDE) (E.D.N.Y.). Rosen\n\nCo-Lead Counsel.\n\n Britton v. Polestar Automotive Holdings UK PLC, No. 25-CV-840-CCC-JBC (D.N.J.).\n\nRosen Co-Lead Counsel.\n\n Karas v. Newmont Corp., No. 25-cv-341-DDD-KAS (D. Colo.). Rosen Co-Lead Counsel.\n\n Cai v. Visa, Inc., No. 24-CV-8220-NW (N.D. Cal.). Rosen Lead Counsel.\n\n Buathongsri v. Zenas Biopharma, Inc., No. 25-cv-10988-FDS-JDH (D. Mass.). Rosen\n\nLead Counsel.\n\n In re Micron Technology, Inc. Sec. Litig., No. 25-cv-191-BLW (D. Idaho). Rosen Co-\n\nLead Counsel.\n\n Weber v. Nextracker, Inc., Nop. 24-cv-9467-PCP (N.D. Cal.). Rosen Lead Counsel.\n\n Ishak v. WM Technology, Inc., No. 24-cv-8959 (C.D. Cal.). Rosen Lead Counsel.\n\n Baker v. Cummins, Inc., No. 25-cv-430-TWP-MWK (S.D. Ind.). Rosen Lead Counsel.\n\n Collura v. Warner Bros. Discovery Inc., No. 24-cv-9027 (KPF) (S.D.N.Y.). Rosen Co-\n\nLead Counsel.\n\n Lin v. TMC The Metals Company, Inc., No. 24-cv-9684-PA-AJR (C.D. Cal.). Rosen Lead\n\nCounsel.\n\n Banurs v. Li Auto, Inc., No. 24-cv-3470 (DG)(VMS) (E.D.N.Y.). Rosen Lead Counsel.\n\nROSEN LAW FIRM BIOGRAPHY 24\n\f Case 8:25-cv-02581-TDC Document 12-4 Filed 10/06/25 Page 26 of 26\n\n\n\n In re Rocket Pharms. Sec. Litig., No. 3:25-cv-10049-ZNQ-TJB (D.N.J.). Rosen Co-Lead\n\nCounsel.\n\n\n\n\nROSEN LAW FIRM BIOGRAPHY 25\n\f","ocr_status":1,"date_upload":"2026-05-18T06:05:55.048302-07:00","document_number":"12","attachment_number":4,"pacer_doc_id":"093015216058","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 4. Rosen Law Firm Resume","acms_document_guid":""}],"date_created":"2025-12-01T00:06:49.993465-08:00","date_modified":"2026-07-12T22:47:08.598192-07:00","date_filed":"2025-10-06","time_filed":null,"entry_number":12,"recap_sequence_number":"2025-10-06.004","pacer_sequence_number":40,"description":"AFFIDAVIT re 10 MOTION to Appoint Counsel and Appoint Lead Plaintiff by Connor McCreery (Attachments: # 1 Exhibit 1. PSLRA Notice, # 2 Exhibit 2. PSLRA Certification, # 3 Exhibit 3. Loss Chart, # 4 Exhibit 4. Rosen Law Firm Resume)(Kim, Phillip) (Entered: 10/06/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/445672458/","id":445672458,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71033169/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/460378078/","id":460378078,"tags":[],"absolute_url":"/docket/71033169/11/collier-v-altimmune-inc/","date_created":"2025-12-01T00:06:49.937810-08:00","date_modified":"2026-07-12T22:47:08.570604-07:00","sha1":"3c57584875b8c843c8a922d22d9c2465012e52e8","page_count":9,"file_size":285226,"filepath_local":"recap/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.11.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.mdd.587811/gov.uscourts.mdd.587811.11.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 1 of 9\n\n\n\n\n UNITED STATES DISTRICT COURT\n DISTRICT OF MARYLAND\n (Southern Division)\n\n\n DAVE COLLIER, Individually and on Case No: 8:25-cv-02581-TDC\n Behalf of All Others Similarly Situated,\n\n Plaintiff,\n CLASS ACTION\n v.\n\n ALTIMMUNE, INC., VIPIN K. GARG,\n and MATTHEW SCOTT HARRIS,\n\n Defendants.\n\n\n\n MEMORANDUM OF LAW IN SUPPORT OF MOTION OF CONNOR MCCREERY\n\n FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF SELECTION OF\n\n COUNSEL\n\n Movant Connor McCreery (\u201cMovant\u201d) respectfully submits this memorandum of law in\n\nsupport of his motion for an Order, pursuant to Section 21D(a)(3)(B) of the Securities Exchange\n\nAct of 1934 (the \u201cExchange Act\u201d), as amended by the Private Securities Litigation Reform Act\n\nof 1995 (the \u201cPSLRA\u201d):\n\n (a) appointing Movant as Lead Plaintiff for the class of all purchasers or acquirers of\n\nAltimmune, Inc. (\u201cAltimmune\u201d or the \u201cCompany\u201d) securities between August 10, 2023 and June\n\n25, 2025, both dates inclusive (the \u201cClass Period\u201d); and\n\n (b) approving Movant\u2019s selection of The Rosen Law Firm, P.A. as Lead Counsel for\n\nthe Class.\n\n\n\n\n 1\n\f Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 2 of 9\n\n\n\n INTRODUCTION AND BACKGROUND\n\n This action was commenced on August 5, 2025 against the Company, Vipin K. Garg, and\n\nMatthew Scott Harris (collectively, \u201cDefendants\u201d) for violations under the Exchange Act. That\n\nsame day, an early notice pursuant to the PSLRA was published advising class members of,\n\namong other things, the allegations and claims in the complaint, the Class Period, and advising\n\nclass members of their option to seek appointment as Lead Plaintiff. See Ex. 1 hereto.\n\n Defendant Altimmune is a clinical stage biopharmaceutical company that focuses on\n\ndeveloping treatments for obesity and liver diseases.\n\n The alleged misrepresentations in this case focus on Altimmune\u2019s failure to achieve\n\nstatistical significance in its analysis of the fibrosis reduction primary endpoint in its IMPACT\n\nPhase 2b MASH trial (the \u201cTrial\u201d) In pertinent part, the action alleges that Defendants provided\n\nthe public with overwhelmingly positive statements leading up to the announcement of topline\n\nresults that failed to account for the fibrosis reduction observed in the placebo group.\n\n Defendants, the complaint alleges, provided overwhelmingly positive statements to\n\ninvestors while simultaneously misrepresenting and/or concealing material adverse facts\n\nconcerning the true state of the results observed in the Trial. Altimmune\u2019s executives, the\n\ncomplaint alleges, repeatedly touted their positive expectations, and further titled the press release\n\nannouncing the Trial\u2019s topline results \u201cAnnounces Positive Topline Results from the IMPACT\n\nPhase 2b MASH trial of Pemvidutide in the Treatment of MASH,\u201d completely disregarding (the\n\ncomplaint alleges) that one of two primary endpoints was not found to be statistically significant.\n\nIn fact, Defendants spent minimal time discussing the aforementioned failure during an investor\n\ncall hosted by Altimmune pertaining to the topline results, rather stating that Altimmune hoped\n\nfor better results in the Phase 3 trial.\n\n\n 2\n\f Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 3 of 9\n\n\n\n Then, on June 26, 2025, Altimmune published a press release announcing topline results\n\nfor the Trial. In contrast to Defendants providing inflated expectations ahead of these results, the\n\nanalysis revealed a failure to achieve statistical significance in its analysis of the fibrosis reduction\n\nprimary endpoint in the Trial. Specifically, statistical significance was not met due to a higher-\n\nthan-expected placebo response.\n\n The complaint alleges that investors and analysts immediately reacted to Altimmune\u2019s\n\nrevelations. Altimmune stock fell from $7.71 per share to $3.61 per share on June 26, 2025, a\n\n53.17% decline.\n\n As a result of Defendants\u2019 wrongful acts and omissions, and the decline in the market\n\nvalue of the Company\u2019s securities, Movant and other Class members have suffered significant\n\nlosses and damages.\n\n ARGUMENT\n\n I. MOVANT SHOULD BE APPOINTED LEAD PLAINTIFF\n\n The PSLRA directs courts to consider any motion to serve as lead plaintiff filed by class\n\nmembers in response to a published notice of class action by the later of: (i) 90 days after the date\n\nof publication of the notice; or (ii) as soon as practicable after the Court decides any pending\n\nmotion to consolidate. 15 U.S.C. \u00a7 78u-4(a)(3)(B). The PSLRA provides a \u201crebuttable\n\npresumption\u201d that the \u201cmost adequate plaintiff\u201d to serve as lead plaintiff is the person or group\n\nthat:\n\n (aa) has either filed the complaint or made a motion in response to a notice\u2026;\n\n (bb) in the determination of the Court, has the largest financial interest in the relief sought\n\n by the class; and\n\n\n\n\n 3\n\f Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 4 of 9\n\n\n\n (cc) otherwise satisfies the requirements of Rule 23 of the Federal Rules of Civil\n\n Procedure.\n\n15 U.S.C. \u00a7 78u-4(a)(3)(B)(iii).\n\n As set forth below, Movant satisfies all three of these criteria, and thus is entitled to the\n\npresumption of being the \u201cmost adequate plaintiff\u201d for the Class.\n\n A. Movant Is Willing to Serve as Class Representative\n\n Movant has filed herewith a PSLRA certification attesting that he is willing to serve as\n\nrepresentative of the class and remains willing to provide testimony at deposition and trial, if\n\nnecessary. See Ex. 2 hereto. Accordingly, Movant satisfies the first requirement to serve as Lead\n\nPlaintiff for the Class.\n\n B. Movant Has a Substantial Financial Interest in the Action\n\n The PSLRA requires a court to adopt a rebuttable presumption that \u201cthe most adequate\n\nplaintiff \u2026 is the person or group of persons that \u2026 has the largest financial interest in the relief\n\nsought by the class.\u201d 15 U.S.C. \u00a7 78u-4(a)(3)(B)(iii). \u201cWhile the PSLRA does not specify how\n\nwe should decide which plaintiff group has the \u2018largest financial interest\u2019 in the relief sought,\n\nmost courts simply determine which potential lead plaintiff has suffered the greatest total losses.\u201d\n\nTakara Trust v. Molex, 229 F.R.D. 577, 579 (N.D. Ill. 2005). Of the Lax/Olsten-styled1 factors in\n\ndetermining the largest financial interest, the financial loss is the most significant factor. See In\n\nre Fuwei Films Sec. Litig., 247 F.R.D. 432, 437 (S.D.N.Y. 2008). Indeed, \u201cthe best yardstick by\n\nwhich to judge \u2018largest financial interest\u2019 is the amount of loss, period.\u201d In re Bally Total Fitness,\n\nSec. Litig., 2005 WL 627960 * 4 (N.D. Ill. Mar. 15, 2005).\n\n\n\n\n1\n Lax v. Merch. Acceptance Corp., 1997 WL 461036 *5 (N.D. Ill. Aug. 11, 1997); In re Olsten\nCorp. Sec. Litig., 3 F.Supp.2d 286, 295 (E.D.N.Y. 1998).\n 4\n\f Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 5 of 9\n\n\n\n Movant lost $22,735.43 in connection with his purchases of Altimmune securities. See\n\nEx. 3 hereto. Movant is not aware of any other movant that has suffered greater losses in\n\nAltimmune securities during the Class Period. Accordingly, Movant satisfies the largest financial\n\ninterest requirement to be appointed as Lead Plaintiff for the class.\n\n C. Movant Satisfies the Requirements of Rule 23 of the Federal Rules of Civil Procedure\n\n Section 21D(a)(3)(B)(iii)(I)(cc) of the PSLRA further provides that, in addition to\n\npossessing the largest financial interest in the outcome of the litigation, the Lead Plaintiff must\n\n\u201cotherwise satisf[y] the requirements of Rule 23 of the Federal Rules of Civil Procedure.\u201d Rule\n\n23(a) provides that a party may serve as a class representative if the following four requirements\n\nare satisfied:\n\n (1) the class is so numerous that joinder of all members is impracticable, (2) there\n are questions of law or fact common to the class, (3) the claims or defenses of the\n representative parties are typical of the claims or defenses of the class, and (4) the\n representative parties will fairly and adequately protect the interests of the class.\n\n In making its determination that the Lead Plaintiff satisfies the requirements of Rule 23,\n\nthe Court need not raise its inquiry to the level required in ruling on a motion for class certification\n\n\u2013 a prima facie showing that Movant will satisfy the requirements of Rule 23 is sufficient. Fuwei\n\nFilms, 247 F.R.D. at 439 (only a prima facie showing is required). Moreover, \u201ctypicality and\n\nadequacy of representation are the only provisions relevant to a determination of lead plaintiff\n\nunder the PSLRA.\u201d In re Oxford Health Plans, Inc. Sec. Litig., 182 F.R.D. 42, 49 (S.D.N.Y.\n\n1998).\n\n 1. Movant\u2019s Claims are Typical\n\n The Rule 23(a) typicality requirement is satisfied when a plaintiff\u2019s claims arise from the\n\nsame event, practice or course of conduct that gives rise to other class members\u2019 claims and\n\nplaintiff\u2019s claims are based on the same legal theory. See In re Livent, Inc. Noteholders Sec. Litig.,\n\n 5\n\f Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 6 of 9\n\n\n\n210 F.R.D. 512, 516 (S.D.N.Y. 2002). Rule 23 does not require the lead plaintiff to be identically\n\nsituated with all class members. Id.\n\n Here, Movant\u2019s claims are typical of the claims asserted by the Class. Movant, like all\n\nmembers of the Class, alleges that Defendants violated the Exchange Act by issuing false and\n\nmisleading statements about Altimmune\u2019s business. Movant\u2019s interests are closely aligned with\n\nthe other Class members\u2019 and Movant\u2019s interests are, therefore, typical of the other members of\n\nthe Class.\n\n 2. Movant Is Adequate\n\n The adequacy of representation of Rule 23 is satisfied where it is established that a\n\nrepresentative party has the ability to represent the claims of the class vigorously, has obtained\n\nadequate counsel, and there is no conflict between a potential representative\u2019s claim and those\n\nasserted on behalf of the class. In re Cendant Corp. Litigation, 264 F.3d. 201, 265 (3d Cir. 2001).\n\n Here, Movant has communicated with competent, experienced counsel concerning this\n\ncase, and made this motion to be appointed as Lead Plaintiff. Movant is not aware that any conflict\n\nexists between his claims and those asserted on behalf of the Class. Movant also sustained\n\nsubstantial financial losses from investments in Altimmune securities and is therefore, extremely\n\nmotivated to pursue claims in this action.\n\n D. Movant Is Presumptively the Most Adequate Plaintiff\n\n The presumption in favor of appointing Movant as Lead Plaintiff may be rebutted only\n\nupon proof \u201cby a purported member of the Plaintiffs\u2019 class\u201d that the presumptively most adequate\n\nplaintiff:\n\n (aa) will not fairly and adequately protect the interests of the class; or\n\n\n\n\n 6\n\f Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 7 of 9\n\n\n\n (bb) is subject to unique defenses that render such plaintiff incapable of adequately\n\n representing the class.\n\n15 U.S.C. \u00a7 78u-4(a)(3)(B)(iii)(I).\n\n The presumption that Movant is the most adequate Lead Plaintiff is not, therefore subject\n\nto rebuttal. Accordingly, Movant has suffered financial losses and has the largest financial interest\n\nin this case of any timely lead plaintiff. The ability of Movant to represent the Class fairly and\n\nadequately is discussed above. Movant is not aware of any unique defenses Defendants could\n\nraise against him that would render Movant inadequate to represent the Class. Movant lives in\n\nAustin, Texas.\n\n II. MOVANT\u2019S SELECTION OF COUNSEL SHOULD BE APPROVED\n\n The PSLRA vests authority in the Lead Plaintiff to select and retain Lead Counsel, subject\n\nto the approval of the Court. 15 U.S.C. \u00a7 78u-4(a)(3)(B)(v). The Court should only interfere with\n\nLead Plaintiff\u2019s selection when necessary \u201cto protect the interests of the class.\u201d 15 U.S.C. \u00a7 78u-\n\n4(a)(3)(B)(iii)(II)(aa).\n\n Movant has selected The Rosen Law Firm, P.A. as Lead Counsel. The firm has been\n\nactively researching Movant\u2019s and Class Plaintiffs\u2019 claims, as well as reviewing publicly available\n\nfinancial and other documents while gathering information in support of the claims against\n\nDefendants. Furthermore, the firm is experienced in the area of securities litigation and class\n\nactions, and has successfully prosecuted securities litigation, securities fraud class actions, and\n\nother complex litigation and obtained substantial recoveries on behalf of investors. See Exs. 4.\n\n As a result of the firm\u2019s experience in litigation involving issues similar to those raised in\n\nthis action, Movant\u2019s counsel has the skill and knowledge to prosecute this action effectively and\n\n\n\n\n 7\n\f Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 8 of 9\n\n\n\nexpeditiously. Thus, the Court may be assured that by approving Movant\u2019s selection of Lead\n\nCounsel, the members of the class will receive the best legal representation available.\n\n CONCLUSION\n\n For the foregoing reasons, Movant respectfully requests the Court issue an Order: (1)\n\nappointing Movant as Lead Plaintiff of the Class; and (2) approving Movant\u2019s selection of The\n\nRosen Law Firm, P.A. as Lead Counsel; and (3) granting such other relief as the Court may deem\n\nto be just and proper.\n\n\n\n\nDated: October 6, 2025 Respectfully submitted,\n\n\n THE ROSEN LAW FIRM, P.A.\n /s/ Phillip Kim\n Phillip Kim, Esq.\n 275 Madison Avenue, 40th Floor\n New York, NY 10016\n Telephone: (212) 686-1060\n Fax: (212) 202-3827\n Email: philkim@rosenlegal.com\n\n [Proposed] Lead Counsel for Lead Plaintiff\n and Class\n\n\n\n\n 8\n\f Case 8:25-cv-02581-TDC Document 11 Filed 10/06/25 Page 9 of 9\n\n\n\n\n CERTIFICATE OF SERVICE\n\n I hereby certify that on October 6, 2025, a true and correct copy of the foregoing document\nwas served by CM/ECF to the parties registered to the Court\u2019s CM/ECF system.\n\n\n /s/ Phillip Kim\n\n\n\n\n 9\n\f","ocr_status":1,"date_upload":"2026-05-18T06:05:48.827128-07:00","document_number":"11","attachment_number":null,"pacer_doc_id":"093015216037","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""}],"date_created":"2025-12-01T00:06:49.892741-08:00","date_modified":"2026-07-12T22:47:08.548298-07:00","date_filed":"2025-10-06","time_filed":null,"entry_number":11,"recap_sequence_number":"2025-10-06.003","pacer_sequence_number":37,"description":"Memorandum re 10 MOTION to Appoint Counsel and Appoint Lead Plaintiff filed by Connor McCreery.(Kim, Phillip) (Entered: 10/06/2025)","tags":[]}],"entries_total":"https://www.courtlistener.com/api/rest/v4/docket-entries/?count=on&docket=71033169&page_size=40"}