>you can’t gain any advantage over the market that overcome your transaction costs

I know this is the predominant efficient market adage but is there a case to be made for low volatility portfolios outperforming the market over long periods? [1]

I’m curious especially now that most online brokers have significantly reduced trade costs on ETFs

[1] https://archivefda.dlib.nyu.edu/jspui/bitstream/2451/29593/2...