On May 25th, the Sixth Circuit reinstated a securities fraud lawsuit against Dana Corp. and its executives, explicitly abandoning its previous approach for determining whether a plaintiff's scienter allegations are sufficient. Instead of viewing each allegation individually before looking at them as a whole, the Court, applying the Supreme Court's opinion in Matrixx Initiatives v. Siracusano, employed a holistic approach and found the instant allegations sufficient. The Court further held that good faith is an affirmative defense in claims under Section 20 of the Securities Exchange Act, and that plaintiffs are thus not required to plead. Frank v. Dana Corp.