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For decades, the volume of securities class actions has grown. Initially most were filed in federal court,1 but the number of securities class actions filed in state court has increased steadily and in 2010 surpassed the number of federal court filings.2 Recognizing the "ways in which the class action device was being used to injure ‘the entire U.S. economy,’" Congress passed the Private Securities Litigation Reform Act (PSLRA) in 1995. The PSLRA, Pub. L. No. 104-67, 109 Stat. 737 (1995), introduced heightened procedural standards in federal court by: (1) limiting plaintiffs’ recovery of damages and attorney fees; (2) mandating a discovery stay until the resolution of any motion to dismiss; and (3) imposing heightened pleading requirements.3

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