On October 13th, the Eastern District of Louisiana, after a bench trial, entered judgment in favor of Morgan Keegan in a securities fraud suit stemming from its sale of auction rate securities ("ARS"). The Court held that plaintiff failed to prove reliance. Even assuming, arguendo, a "fraud created the market" theory of reliance, plaintiff's claim falls because the ARS were not worthless from their inception. Fishman v. Morgan Keegan & Co