By Nathaniel Cartmell III and Bruce Ericson ( September 15, 2017, 11:56 AM EDT) -- The Private Securities Litigation Reform Act of 1995 protects "forward-looking statements" — that is, predictions about the future, at least when they are accompanied by "meaningful cautionary statements" that could cause the predictions not to come true. But what if the prediction is presented with, and based upon, statements of current fact? Does the protection extend to the predicate for the prediction? Or must a court parse the two and apply different rules to each? In what it labels a matter of first impression, the Ninth Circuit has held that courts must parse the two, suggesting that nothing short of an admission of falsity would save a false statement of current fact, even if presented only as a predicate for a prediction of the future....