This article addresses the lower courts’ application of the Supreme Court’s recent class action securities decision in Halliburton Co. v. Erica P. John Fund, Inc., 134S.Ct. 2398, 2412 (2014), which permits defendants to rebut fraud-on-the-market reliance at the class certification stage.  The article will also seek to provide securities litigators with the lay of the land post-Halliburton.