A Checklist of key issues and defenses that counsel should consider when moving for summary judgment in a private action alleging material misstatements or omissions in violation of Section 10(b) of the Securities Exchange Act of 1934 and its implementing regulation, Securities and Exchange Commission Rule 10b-5. In securities fraud cases, defense counsel often rely on motions for summary judgment to narrow or eliminate the plaintiff's claims and potentially gain leverage in post-motion settlement discussions. This Checklist sets out the substantive grounds supporting summary judgment motions in federal court and key strategic and procedural considerations.