On December 13th, the Oregon Supreme Court held that a stock purchaser alleging material misrepresentations in the sale of securities in violation of the state's blue sky laws may establish reliance by means of the "fraud-on-the-market" presumption. The state of Oregon purchased more than $15 million of common stock in March & McLennan in the open market at allegedly inflated prices. The state contends that Marsh made three types of misrepresentations which when revealed, caused the stock to decline by 37 percent. State v. Marsh & McLennan Companies, Inc.