Scheme liability, class certification, concurrent jurisdiction, and loss causation are issues to watch in 2019. In Lorenzo, the Supreme Court could clarify who can be liable for making misstatements under Rule 10b-5(b), what conduct triggers scheme liability under Rules 10b-5(a) and (c), and where to draw the line between primary and secondary liability. In In re Goldman Sachs Group, the Second Circuit could refine recent rulings that have eased the way for plaintiffs to establish market efficiency to invoke the fraud on the market presumption of reliance at the class certification stage. After Cyan — in which the Supreme Court ruled that SLUSA did not end concurrent jurisdiction over Securities Act class actions — state courts have seen a spike in Securities Act filings (see table), a trend that might persist unless state court judges signal that they will honor the Reform Act’s procedural protections. Finally, the Supreme Court could take up First Solar, in which the Ninth Circuit held that loss causation is established if a stock-price drop is caused by misstatements or omissions of fact, even if the market is unaware of the fraud.