On March 21st, the U.S. District Court for the Southern District of New York granted plaintiffs' motion for class certification in their lawsuit against an executive at the Smith Barney Family of Funds. Plaintiffs allege the executive failed to disclose that Smith Barney's use of an affiliated transfer agent cost the funds less than before, and failed to pass-on those cost savings to investors. In its order, the District Court addresses typicality noting that plaintiffs, even had they participated in the SEC's earlier Fair Fund distribution, may not have been made whole. Discussing predominance, the Court holds plaintiffs' are entitled to the Affiliated Ute presumption of reliance in connection with claims involving a failure to disclose. In re Smith Barney Transfer Agent Litigation.