Securities Law | Expert Legal Commentary
December 12, 2008
In re Salomon Analyst Metromedia Litig.: Rebuttable Presumption of Fraud-on-the-Market Extended to Analysts
In re: Salomon Analyst Metromedia Litigation
By
Joel B. Ginsberg
In Douglas Millowitz v. Citigroup Global Markets et al (“In Re Salomon Analyst Metromedia Litigation”), 544 F.3d 474 (2nd Cir. 2008), the Second Circuit extended the fraud-on-the-market presumption of reliance, first set forth in Basic v. Levinson, 485 U.S. 224 (1988), to analyst reports. The Court also stated that defendants should be afforded the opportunity to rebut that presumption at the class certification stage in an effort to prevent certification. The opinion may make it harder to pursue class actions in some securities fraud cases.
To continue reading this article, subscribe now
It's FREE and only takes seconds
Image Credit: ©iStockphoto.com/sgame
View a PDF of the judicial opinion
