DENVER >> A judge says lawsuits can move forward against the owner of the Colorado movie theater where a gunman killed 12 people and injured 70 others in 2012.

The Denver Post reports that U.S. District Judge R. Brooke Jackson ruled Friday that Cinemark could have predicted moviegoers might be targeted for an attack, noting "the grim history" of mass killings in recent times.

Jackson writes that although theaters had until then avoided a mass shooting, moviegoers are "perhaps even more than students in a school or shoppers in a mall, ‘sitting ducks.’"

The ruling, which allows 20 lawsuits to advance, didn’t decide if Cinemark did enough to try to prevent the shooting in the Denver suburb of Aurora. Cinemark didn’t immediately return a phone message left by The Associated Press on Saturday.