In a matter of first impression, a U.S. Court of Appeals for the Ninth Circuit panel in Pirani v. Slack Technologies, 13 F.4th 940 (9th Cir. 2021), wrestled with its own prior holding that a plaintiff bringing a claim under Section 11 of the Securities Act of 1933 must have purchased a security issued under a specific registration statement and its concern that, in a direct listing, it may be impossible for any plaintiff to ever know, or prove, that the shares he purchased were among the shares formally registered through the company's registration statement as opposed to other unregistered shares. In deciding that an investor purchasing through a direct listing could establish standing under Section 11, the Ninth Circuit departs from past precedent and abandons the previously strict tracing requirement courts have historically interpreted under Section 11.