Proximity is easy to establish when the investors are members of a very limited class as in Haig v. Bamford, 1976 CanLII 6 (SCC), [1977] 1 S.C.R. 466, [1976] 3 W.W.R. 331, 27 C.P.R. (2d) 149, 72 D.L.R. (3d) 68, 9 N.R. 43 [Sask.]. It is a good deal more difficult to establish when the investors are members of the public at large to whom had been extended an invitation to purchase the notes in question.
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