to establishing the fact of the defendant’s liability: “Challenges based on ... reliance have usually been rejected and will not bar predominance satisfaction because [reliance pertains] to the right of a Class Member to recover in contrast to underlying common issues of the defendant’s liability.” 1 Newberg § 4.26, at 4-104. Where all class members must establish the defendant’s complicity and liability, thus, the individual issues are secondary and the class should be certified. See In re IGI Sec. Litig., 122 F.R.D. at 460. Even if many of the plaintiffs’ claims involved a reliance element, thus, common issues would predominate. 64. But in this case most of the plaintiffs’ claims do not even involve a reliance element. Plaintiffs’ claims Co., 980 F.2d 912, 924 (3d Cir.1992) (<HOLDING>); Sharp, 70 F.R.D. at 547 (“One of the two
recognizing presumption holding that a presumption of fraud eliminates the need to prove reliance holding that plaintiffs were entitled to the ute citizens presumption of reliance recognizing a rebuttable presumption of reliance in rule 10b5 holding that plaintiffs were not entitled to a preliminary injunction