Courts generally focus on the liability issue in deciding whether the predominance requirement is met, and if the liability issue is common to the class, common questions are held to predominate over individual questions

The proper inquiry is whether other members of the class have the same or similar injury, whether the action is based on conduct not special or unique to the named plaintiffs, and whether other class members have been injured by the same course of conduct.

In the context of a class certification and the defendants' argument that individual issues of fact predominated, the court indicated that a relevant issue was whether the defendants "relied on inside information in making... trading decisions

Moreover, class representatives have "pursue [d] a resolution of the controversy in the interests of the class."

The typicality prerequisite overlaps with the common question requirement of Rule 23 (a)(2) and the adequate representation requirement of Rule 23 (a)(4

In order to satisfy the typicality requirement, the class representative's claims must "arise [] from the same event or course of conduct that gives rise to claims of other class members and the claims [must be] based on the same legal theory. By advancing their own interests, plaintiffs will advance the interests of the class."

"[I] ndividual issues will likely arise in... all class action cases. But, to allow various secondary issues of plaintiffs' claim to preclude certification of a class would render the rule an impotent tool for private enforcement of the securities laws."

Further, even though the elements of “economic loss” and “loss causation” may require individualized proof, courts generally focus on issues related to liability in determining predominance.

As courts in securities fraud cases have observed, "[t] he categories of `omission'and `misrepresentation'are not mutually exclusive. All misrepresentations are also nondisclosures, at least to the extent that there is a failure to disclose which facts in the representation are not true. "

There is no doubt that the "existence, materiality, and character of the alleged misrepresentations and omissions" in this securities action constitute common questions.