According to the Complaint, Norfolk Southern Corporation is a major rail transportation company primarily focused on the transport of raw materials, intermediate products, and finished goods across the Southeast, East, and Midwest United States. In 2019, the Company adopted a “Precision Scheduled Railroading” (“PSR”) strategy, which was designed to increase revenues and decrease costs by enacting hyper-efficient operational changes like reductions in staff, tighter schedules, and longer trains that can stretch up to miles in length.

This case is filed on behalf of all persons and entities that purchased or otherwise acquired Norfolk Southern senior notes (the “Senior Notes”) pursuant, or traceable, or both, to materials issued in connection with offerings conducted by the Company on or around August 18, 2020, May 3, 2021, August 16, 2021, February 15, 2022, June 2, 2022, and January 26, 2023 (the “Offerings”).

The Complaint alleges that materials issued in connection with the Offerings (the “Offering Materials”) were negligently prepared and, as a result, contained untrue statements of material fact or omitted to state other facts necessary to make the statements made not misleading and were not prepared in accordance with the rules and regulations governing their preparation. Specifically, the Complaint alleges the statements contained in the Offering Materials were materially false and misleading when made because the Offering Materials touted the Company’s focus on safety and environmental protection while failing to disclose the following adverse facts that existed at the time of the Offerings that were later disclosed to the public: (1) the PSR strategy had led to increased train derailments and an increased risk of future derailments; (2) the PSR strategy was part of a culture of increased risk-taking at the expense of reasonable safety precautions due to the Company’s near-term focus on profits; (3) the Company was more vulnerable to train derailments; (4) Norfolk Southern’s capital spending and replacement programs were designed to prioritize profits over the Company’s ability to provide safe, efficient, and reliable rail transportation services; (5) the Company’s lobbying efforts had undermined its ability to provide safe, efficient, and reliable rail transportation services; (6) the PSR strategy undermined worker safety and the Company’s purported “commitment to an injury-free workplace” because the Company’s PSR plan prioritized reducing expenses through fewer personnel, longer trains, and less spending on safety training, technology, and equipment; (7) the PSR strategy rendered Norfolk Southern more susceptible to accidents that could cause serious economic and bodily harm; and (8) the Company failed to put in place responsive practices and procedures to minimize the threat to communities in the event that these communities suffered the derailment of a Norfolk Southern train carrying hazardous and toxic materials. The undisclosed adverse facts and circumstances detailed above made an investment in the Senior Notes speculative or risky, and presented known trends, uncertainties, and risks that required disclosure in the Offerings Materials which were not disclosed, including adverse trends and risks related to the safety of Norfolk Southern’s operations.

On September 21, 2023, the Court issued an Order appointing Lead Plaintiffs and Counsel. Lead Plaintiffs filed an amended Complaint on December 4. Defendants filed a Motion to Dismiss the amended Complaint on February 2, 2024.

On February 27, 2025, the Court issued an Order granting Defendants' Motion to Dismiss.