To prove loss causation, the ultimate issue is whether the defendant’s misstatement, as opposed to some other fact, foreseeably caused the plaintiff’s loss. Causation can be shown by proof of a drop in stock price after eventual revelation of the truth. But that is only one permissible means of establishing probable cause; it is not the sole or required means of doing so. Accord: Lloyd v. CVB Fin. Corp. (9th Cir. 2016) 811 F.3d 1200, 1210.
Ninth Circuit Court of Appeal (per curiam); January 31, 2018; 2018 WL 626948.