In this Comment, the author attempts to answer the question left open after the passage of the Private Securities Litigation Reform Act ("PSLRA"): who should be the lead plaintiff in securities litigation? That law creates a presumption that the lead plaintiff be "the person or group of persons" with the largest financial interest in the pending suit. Although the legislative history accompanying the Act demonstrates that Congress intended to favor institutional investors when drafting this provision, courts have sometimes construed it to permit them to combine the losses of unrelated plaintiffs and appoint them instead of institutional investors. In Part I, the author summarizes the PSLRA’s lead plaintiff provision and the reasons that led Congress to restructure how plaintiffs were selected to lead securities fraud suits. In Part II, he analyzes the case law interpreting the PSLRA, in light of the courts’ treatment of similar issues before Congress passed the PSLRA. Finally, in Part III, the author uses this analysis to recommend when courts should appoint institutional investors or groups of institutions or individuals to represent the class.