What is the burden of pleading in loss causation?

What we are here describing is the burden of pleading, which has clearly been met by a plaintiff's allegation of a misrepresentation that goes to how well the house was built, as well as the burden of introducing some counterevidence (onus procedendi), which has shifted to the defendant. Cf. Liriano v. Hobart Corp., 170 F.3d 264, 272 (2d Cir. 1999) ("This shifting of the onus procedendi has long been established in New York."). The essential point for present purposes is that where a potential causal link is evident, it is not necessary for the plaintiff to plead loss causation in detail to render her fraud claim plausible at the motion-to-dismiss stage.