Erica P. John Fund, Inc. v. Halliburton Co. Case Brief

Facts of the Case

Petitioner Erica P. John Fund, Inc. (EPJ Fund), was the lead plaintiff in a putative securities fraud class action filed against Halliburton Co. and one of its executives (collectively Halliburton). EPJ Fund alleged that Halliburton made various misrepresentations designed to inflate the company’s stock price, in violation ofof the Securities Exchange Act of 1934 and Securities and Exchange Commission. EPJ Fund also contended that Halliburton later made a number of corrective disclosures that caused the stock price to drop and, consequently, investors to lose money. EPJ Fund sought to have its proposed class certified pursuant to. The District Court found that the suit could proceed as a class action under, but a Fifth Circuit precedent required securities fraud plaintiffs to prove “loss causation”–

Question

Under the Patent Act, should a permanent injunction always be issued when a patent has been violated, absent exceptional circumstances?

CONCLUSION

“No. The Supreme Court vacated and remanded the lower court order in a unanimous opinion by Chief Justice John Roberts. “Securities fraud plaintiffs need not prove loss causation in order to obtain class certification,” the Chief Justice wrote.”

Case Information

Citation: 563 US 804 (2011)
Granted: Jan 7, 2011
Argued: Apr 25, 2011
Decided: Jun 6, 2011
Case Brief: 2011