The Group Published Information Doctrine
"The Ninth Circuit has developed the group published information doctrine which it has described as follows: 'In cases of corporate fraud where false and misleading information is conveyed in prospectuses, registration statements, annual reports, press releases or other "group-published information," it is reasonable to presume that these are the collective actions of the officers.
Under such circumstances, a plaintiff fulfills the particularity requirement of Rule 9(b) by pleading the misrepresentations with particularity and where possible the roles of the individual defendants in the misrepresentations.'
Subsequent decisions have extended the doctrine to cover not only officers but directors as well.
'The rationale for group pleading is that facts about fraud flowing from the internal operation of a corporation are peculiarly, and often exclusively, within the control of the corporate insiders who manage the parts of the corporation involved in the fraud.' " ( In re Interactive Network, Inc. Securities Litigation (N.D.Cal. 1996) 948 F. Supp. 917, 920.)