"Last week, the Second Circuit issued a must-read opinion for securities class action lawyers. In Waggoner et al. v. Barclays PLC, No. 16 Civ. 1912 (2d Cir. Nov. 6, 2017), the Second Circuit held that plaintiffs do not need to present direct evidence of market efficiency (i.e., an event study) in order for a court to certify a class of investors alleging securities fraud under federal law. Indirect evidence may be enough to demonstrate an efficient market."