On December 3rd, the Sixth Circuit affirmed the dismissal of state law claims brought against various credit rating agencies. Institutional investors who purchased mortgage-backed securities receiving AAA (or the equivalent) credit ratings sued the ratings agencies after the value of the MBS collapsed. Affirming the dismissal of plaintiffs' negligent misrepresentation claim, the Sixth Circuit held the credit raters owed no duty of care to plaintiffs and the ratings were not actionable misrepresentations. Plaintiffs' assertion that the agencies did not believe in the correctness of their ratings was unreasonable. Plaintiffs' claims under Ohio blue sky law were similarly dismissed. Ohio Police & Fire Pension Fund v. Standard & Poor's Financial Services LLC.