On May 16th, the U.S. District Court for the Northern District of California held that loss causation must be established even in cases involving illiquid securities. Here, institutional investors who purchased municipal revenue bond anticipation notes alleged that the offering statement contained fraudulent misrepresentations. Entering summary judgment dismissing the federal securities fraud claims, the Court held that even though the market for the notes was inefficient, plaintiffs still needed to raise a triable issue of fact as to loss causation, which they failed to do. In re: Nuveen Funds/City of Alameda Securities Litigation.