On August 13th, the Second Circuit vacated and remanded the district court's order denying a motion to certify a settlement class. Plaintiffs' securities fraud lawsuit stems from AIG's alleged fraudulent use of reinsurance contracts to inflate its financial statements. The parties reached a settlement agreement and asked that a settlement class be certified. Denying certification, the district court held the class did not satisfy the predominance requirement of Rule 23(b)(3) because the fraud-on-the-market presumption did not apply. Vacating, the Second Circuit holds that a class' failure to satisfy the fraud-on-the-market presumption threatens class certification by creating trial management problems. Because settlement eliminates a trial, a settlement class need not show that the fraud-on-the-market presumption applies to its claims to satisfy the predominance requirement. In re American International Group, Inc. Securities Litigation.