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Over the past twenty years, the efficient capital market hypothesis ("ECMH") has risen to a prominent position in financial and economic theory.' In its most commonly held form-known as "semi-strong"-the ECMH states that the securities markets incorporate all available public information so rapidly that investors cannot develop a trading rule (including one based on research into company or industry fundamentals) that will systematically yield greater returns than the market. Recently, however, theorists have increasingly questioned the ECMH. These theorists argue that irrational behavior and limited informationprocessing abilities can keep the price of securities at levels that do not reflect their fundamental values.2

Implications of the Private Securities Litigation Reform Act of 1995 for Judicial Presumptions of Market Efficiency