The Supreme Court's decision in Dura Pharmaceuticals, holding that a securities law plaintiff must plead loss causation, continues to have a significant impact on pleading a cause of action for securities fraud in damage cases. While the decision resolved a split among the Circuits regarding loss causation, it appears that a new split may be emerging over the application of Dura. Join Tom Gorman as he analyzes the Dura decision and its impact on securities damages actions through a series of Circuit Court decisions and explores whether a new split is emerging among the Circuits.