On February 12th, the Fifth Circuit affirmed a trial court's denial of class certification in a securities fraud lawsuit. In doing so, the Court reiterated that Circuit law requires plaintiffs to establish loss causation by a preponderance of all admissible evidence in order to trigger the fraud-on-the-market presumption at the class certification stage. Plaintiffs must show the joinder of an earlier false statement by defendant, a subsequent corrective disclosure and a subsequent loss that cannot be otherwise explained. The Archdiocese of Milwaukee Supporting Fund, Inc. v. Halliburton Co.