Deloitte & Touche was a primary target of the various plaintiffs attempting to hold someone responsible for the Livern debacle and the resulting financial losses. In December 1999 a U.S. federal judge dismissed Deloitte as a defendant in one of those lawsuits filed by Livent’s former stockholders. The judge concluded that the plaintiffs had not made a reasonable argument that Deloitte was at least reckless in auditing Livent. For lawsuits filed under the Securities and Exchange Act of 1934 as amended by the Private Securities Litigation Reform Act of 1995 plaintiffs must allege or plead that the given defendant was at least reckless.