How does the affirmative defense of negative causation work?

For claims brought under Section 11 of the Securities Act of 1933, "[t]he affirmative defense of negative causation prevents recovery for losses that the defendant proves are not attributable to the alleged misrepresentation or omission in the registration statement." Hildes v. Arthur Andersen LLP, 734 F.3d 854, 860 (9th Cir. 2013). The defendant bears a "heavy burden" of proof on this defense, and must

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