Based on the lessons from theAffiliated UteCitizens case, why have courts made the reliance element of a Section 10(b) claim so easy to satisfy?

Satisfying the reliance requirement in a Section 10(b) or Rule 10b-5 claim differs depending on whether the securities transaction involved individuals engaged in a personal transaction or actors using an impersonal securities exchange to execute sales and purchases of securities. . In Affiliated Ute [narrator: pronounce "yut," like the "Ut" in "Utah"] Citizens v. United States, the Supreme Court concluded that in face-to-face transactions, a person may successfully establish reliance by demonstrating that her counterparty omitted material facts, in that a reasonable investor would have considered those facts important in making the decision to purchase or sell the security.