Lyndsey B. Campbell

Current Cases

• FMC Corporation

  This securities fraud class action arises out of defendants’ representations and omissions made regarding the demand for FMC’s suite of crop protection products during the COVID-19 pandemic and afterwards. As the realities of supply chain disruptions gripped the world, FMC’s distribution partners sought to purchase as much product as possible. Beginning in 2020 and stretching into 2022, FMC welcomed this boom in sales across all of its products, including its flagship diamide insecticides.

  While this dynamic of extensive overbuying was well known within the Company, investors were kept in the dark as to this practice, which did not represent a new baseline of demand, but would predictably tail off and then cannibalize FMC’s future sales. At the same time, FMC’s diamide insecticides were facing increasing competition from generics being sold at a fraction of the price. In spite of the knowledge that inflated sales trends in 2020 and 2021 were unsustainable, FMC sought to convince the public that the high sales numbers were a new normal with no signs of slowing down, and that generic competition was only a worry in the distant future.

  Plaintiffs allege defendants made repeated representations throughout the Class Period that demand for the Company’s products was robust, and that growth from recent years would continue. However, by 2022, demand for FMC’s products was declining precipitously, as distributors, retailers and end-users held overstuffed inventories and dramatically slowed their buying. This continued into 2023, despite FMC’s extraordinary efforts to jumpstart sales, including through costly incentives and credit arrangements. Then on May 2, 2023, FMC announced to the public that it was lowering its growth expectations for the coming quarter, but still assured investors that there were no further issues to report. On July 10, 2023, FMC again revised down its revenue and EBITDA outlooks for the year, still without disclosing the realities of its demand environment. Then on September 7, 2023, Blue Orca Capital published a report detailing its claim that FMC had “concealed from investors” the deterioration of its core business, creating an “inescapable cycle” of falling revenues, plummeting cash flows and declining profits. The story was not fully unraveled until late October 2023, when FMC admitted to investors that it expected the destocking of client warehouses to extend into 2024, and that its cratering sales numbers and cash flow had driven the Company to renegotiate its credit agreements and begin a full restructuring of its Brazilian operations, the Company’s single largest sales region for the past five years.

  On July 17, 2024, plaintiffs filed a 186-page complaint on behalf of a putative class of investors who purchased FMC common stock between February 9, 2022 and October 30, 2023, alleging violations of Sections 10(b) and 20(a) of the Securities Exchange Act of 1934. On September 17, 2024, the defendants filed a motion to dismiss the complaint. Briefing on the defendants’ motion is now complete and pending before the court. 

• GSK PLC

  This securities fraud class action asserts claims against GlaxoSmithKline plc (“GSK”), a multinational pharmaceutical and biotechnology company, its current CEO, Emma Walmsley, and its former CFO, Iain Mackay. On July 7, 2025, Lead Plaintiff filed the Consolidated Class Action Complaint against GSK and these executives pursuant to Sections 10(b) and 20(a) of the Exchange Act.

  The case arises out of public representations that Defendants made during the Class Period concerning Zantac, a medication to treat heartburn, reflux, and ulcers. From the early 1980s through late-2019, GSK sold this drug to millions of consumers while allegedly knowing that its active ingredient, ranitidine, formed a carcinogenic substance known as “NDMA” both within and outside the human body. Following the revelation of the presence of this carcinogen and the drug’s removal from the market in 2019-2020, GSK faced an onslaught of litigation. Defendants, however, claimed that GSK was still “investigating” the source of the NDMA found in Zantac and assured investors that GSK’s financial and business risk associated with litigation related to Zantac was minimal. 

  Plaintiffs allege that the foregoing representations were materially false or misleading. In this regard, the Complaint alleges that Defendants manufactured Zantac while aware that the drug’s active ingredient formed a carcinogen, NDMA, when interacting with elements normally found in the human digestive system. In 1982, prior to Zantac’s initial FDA approval and public sale the following year, Dr. Richard Tanner, a GSK scientist, documented the degradation of Zantac into NDMA in the “Tanner Study.” Consequently, Defendants were aware prior to the FDA approval of Zantac that the drug’s active ingredient would form a carcinogen. Despite the FDA’s concerns and questions regarding this issue during the drug approval process, GSK dismissed the “possibility of carcinogenesis,” and concealed its knowledge of this carcinogen for decades. The Complaint alleges that the truth contained in the Tanner Study was first revealed to investors and the public following a February 15, 2023 publication of a Bloomberg Businessweek article entitled “Zantac Cancer Risk Data Was Kept Quiet by Manufacturer Glaxo for 40 years.”

  In early 2019, an independent laboratory, Valisure, discovered that OTC Zantac contained significantly more NDMA than the FDA’s daily limit. Based on this finding, Valisure submitted a Citizen’s Petition to the FDA, requesting it be removed from the market. That same year, following Valisure’s revelation to the public of the unsafe levels of NDMA in Zantac, the FDA recalled the drug. However, for years thereafter, GSK continued to conceal from investors and the public the connection between Zantac and NDMA. In particular, Defendants made misrepresentations concerning: (1) GSK’s awareness of carcinogenic issues with Zantac before the FDA reached out in 2019; (2) GSK’s “exposure” to patient safety and product quality risks, which Defendants misleadingly claimed remained “unchanged,” even after GSK belatedly revealed the Tanner Study showing the connection between the drug and NDMA; (3) the FDA’s purportedly thorough reviews of Zantac’s safety, when GSK failed to disclose critical data to the FDA, including the Tanner Study; and (4) the range of GSK’s Zantac-related liability.

  The relevant truth about the connection between NDMA and Zantac, as well as the potential liability for GSK, was revealed through a series of corrective events. First, on August 10, 2022, analysts revealed that GSK’s potential Zantac litigation exposure could be “in the $5-10 billion range.” Additionally, on August 11, 2022, analysts revealed that GSK would bear approximately 80% percent of the Zantac litigation liability—far from GSK’s representations that its risk exposure was “unchanged.” Next, on August 16, 2022, Defendant Mackay confirmed GSK’s exposure was significant, quantifying it to be in the “mid $ billions.” Following these disclosures, GSK’s stock price fell precipitously. The Complaint alleges that GSK’s investors suffered substantial losses as a result of Defendants’ misstatements and omissions being revealed to the market.