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The availability of the fraud on the market presumption of reliance is a linchpin to class certification in most securities fraud suits. If the presumption does not apply, reliance on alleged misrepresentations is an individual issue that in most cases will overwhelm any common issues and preclude class certification. What is the evidentiary predicate for presuming class-wide reliance on alleged material misrepresentations? There is consensus that plaintiffs invoking the fraud on the market theory must establish that the defendants made public misrepresentations that were material, that the relevant security traded on an efficient market, and that the plaintiffs traded in the stock between the time the misrepresentations were made and the time the truth was publicly revealed.

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