(March 15, 2016, 9:23 AM EDT) -- BOSTON — A federal district court erred in dismissing a securities class action lawsuit for failure to properly plead scienter because it impermissibly required a shareholder to plead actual knowledge on the part of defendants in stating its claims for recklessness when making its federal securities law claims, the shareholder argues in a Feb. 3 appellant brief filed in the First Circuit U.S. Court of Appeals (Local No. 8 IBEW Retirement Plan v. Vertex Pharmaceuticals Inc., et al., No. 15-2250, 1st Cir.)....