2. In MATRIXX INITIATIVES, INC. v. SIRACUSANO, 563 U.S. ___, 131 S.Ct. 1309, 179 L.Ed.2d 398 (2011), the Court held that the Tellabsstandard can be satisfied even without

“an allegation of statistical significance to establish a strong inference of scienter,” id. at ___, 131 S.Ct. at 1324, 179 L.Ed.2d at 416. How does the Tellabs standard differ from the requirement of plausibility under Twombly and Iqbal? Has there been a convergence of pleading standards under Federal Rules 8 and 9(b)? See Steinberg & Gomez-

Cornejo, Blurring the Lines Between Pleading Doctrines: The Enhanced Rule 8(a)(2)

Plausibility Pleading Standard Converges with the Heightened Fraud Pleading Standards under Rule 9

(b) and the PSLRA, 30 Rev. Litig. 1 (2010).