Law360, New York ( May 27, 2016, 11:35 AM EDT) -- In a recent decision, IBEW Local 98 Pension Fund v. Best Buy Co. Inc., __ F.3d __, (8th Cir. April 12, 2016), the Eighth Circuit became the first federal appellate court to address the issue of "price impact" on a motion for class certification in light of the U.S. Supreme Court's decision in Erica P. John Fund Inc. v. Halliburton Co., 134 S. Ct. 2398 (2014) ("Halliburton II"). In Halliburton II, the Supreme Court reaffirmed the principle that a plaintiff seeking class certification may rely on the fraud on the market's presumption of reliance, but ruled that a defendant may rebut such presumption by presenting evidence that the alleged misrepresentation did not result in any "price impact" with respect to the security at issue....