In the last issue of the Securities Regulation Law Journal, Professor
Ted Fiflis questioned the analysis of the Supreme Court's Gustafson de
cision, which held that Section 12 (2) relief is limited to buyers in
public offerings. This article continues that analysis by examining se
veral lower court cases decided since Gustafson. Based on these recent
decisions, the author sees further turmoil in securities law and prac
tice.