On June 21, 2021, the U.S. Supreme Court held in Goldman Sachs Group Inc. v. Arkansas Teacher Retirement System, No. 20-222 (2021), that courts may consider at the class certification stage the generic nature of alleged misrepresentations as evidence of the lack of price impact in determining whether a defendant has rebutted the presumption of classwide reliance recognized in Basic Inc. v. Levinson, even though this may entail overlap with the merits question of materiality. The Court further held that defendants seeking to rebut the Basic presumption bear not only the burden of production, but also the ultimate burden of persuasion to prove lack of price impact by a preponderance of the evidence.