Second Circuit Confirms That Statements of Opinion Need Not Be Accompanied by Disclosure of All Underlying Conflicting Information On May 1, 2018, in Martin Quartermain, No. 17-2135 (2d Cir. May 1, 2018), the Second Circuit reiterated that plaintiffs must overcome a high bar to plead an actionable misstatement of opinion under Section 10(b) of the Securities Exchange Act of 1934 (the "Exchange Act"). When an issuer's opinion is honestly held and the issuer has a reasonable basis for its belief, disclosure of underlying conflicting information is not required—"even when the 'fact' cutting the other way is the contrary opinion of an expert or authority." The decision is the second time that the Second Circuit has meaningfully discussed the Supreme Court's 2015 decision in Omnicare, Inc. v. Laborers District Council Construction Industry Pension Fund. The Second Circuit's decision in Martin reaffirmed its prior holding in Tongue v.