Mealey's (June 29, 2021, 1:11 PM EDT) -- SAN FRANCISCO — In a 2-1 ruling in a “mixed” securities fraud class action lawsuit against Volkswagen Aktiengesellschaft (VWAG) and others, a Ninth Circuit U.S. Court of Appeals panel on June 25 held that a federal district court erred in applying the presumption of reliance standard set forth by the U.S. Supreme Court in Affiliated Ute Citizens of Utah v. United States when it denied VWAG’s summary judgment motion because shareholder allegations “cannot be characterized primarily as claims of omission.”...