How have courts interpreted the antifraud provisions of section 14 of the Ontario Anti-Fraud Act?

Perhaps the first case in this circuit to interpret the antifraud provisions of section 14 was Doyle v. Milton, 73 F.Supp. 281 (S.D.N.Y.1947). The court held there that motivation, not otherwise unlawful, is not a required disclosure under the Act. Id. at 286. From that early date to the present time, our district judges consistently have reasoned in the same manner. See, e.g.:

Stedman v. Storer, 308 F.Supp. 881, 887 (S.D.N.Y.1969) (no material omission in directors' failure to discover and adjudge faithless motives for their actions and announce the same);