Indeed, there is academic research substantiating the concern that state court judges grant motions to dismiss in Securities Act liability actions less frequently than federal court judges. In their October 2019 paper (here), Stanford Law School Professor Michael Klausner and his colleagues found that since the Cyan decision, motions to dismiss Section 11 cases were granted in only 19% of state court cases, while the motion were granted 42% of the time in federal court cases.