In the SolarWinds case, the court dismissed the SEC's material omission claims and noted that the SEC's allegations "impermissibly rely on hindsight and speculation" and found that disclosure must be "[r]ead fairly and in totality" and that "perspective and context are critical." In addition, the court dismissed the SEC's allegation that SolarWinds' cyber risk disclosure was generic and created a misleading picture. The court held that fraud claims based on risk disclosures are uncommon and actionable only in "narrow circumstances" and that such risk disclosure did not require the level of specificity for which the SEC argued.