Grant Mainland, Jed Schwartz, Joseph DaSilva
January 24, 2026
Milbank Litigators Review Recent Developments in Securities Class Actions in New York Law Journal Article

1 min
AI-made summary
- An article in the New York Law Journal by Milbank LLP attorneys examines recent developments in securities class actions relevant to defendants in Section 10(b) cases
- The authors discuss the Supreme Court’s Goldman Sachs decision on considering the generic nature of misrepresentations at class certification, address whether stock drops from market speculation are recoverable as damages, and note a trend among Second Circuit district courts measuring the Exchange Act’s statute of repose from each alleged misrepresentation date.
In an article published in the New York Law Journal, Milbank LLP Litigation & Arbitration partners Grant Mainland and Jed Schwartz, and associate Joseph DaSilva, discuss recent developments in securities class actions that defendants in §10(b) cases should consider in crafting their litigation strategy.~~In âRecent Developments in Securities Class Actions: âGoldmanâ, Market Speculation and Loss Causation, and Triggering the Exchange Actâs Statute of Repose,â the authors focus on three topics: (1) the Supreme Courtâs decision in Goldman Sachs Group v. Arkansas Teacher Retirement System clarifying that courts should consider the generic nature of a misrepresentation as part of price impact disputes at the class certification stage; (2) cases addressing whether stock drops resulting from market speculation are recoverable as securities fraud damages under Dura Pharmaceuticals v. Broudo and progeny; and (3) a growing consensus among district courts in the Second Circuit that the Exchange Actâs statute of repose is measured from the date of each alleged misrepresentation, rather than the last one.~~To access the full PDF of the article, "Recent Developments in Securities Class Actions: 'Goldman', Market Speculation and Loss Causation, and Triggering the Exchange Act's Statute of Repose," please click here.
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Grant Mainland, Jed Schwartz, Joseph DaSilva
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