What is the pleading in pleading in a class action alleging misrepresentation in the secondary market?

In considering the pleading as a whole, it is appropriate to note that this is a multi-billion dollar class action. It has been commenced by very experienced securities lawyers. These same counsel acted for the class in McCann v. CP Ships, which was decided more than a year before this action was commenced. This action asserts complex common law and statutory remedies for misrepresentation in the secondary market. It is inconceivable that counsel would have asserted a s. 130 claim without specifically pleading the section or referring to the prospectus containing the alleged misrepresentation. It is inconceivable that they would not have included a prospectus purchaser as a representative plaintiff or at least asserted a claim on behalf of prospectus purchasers.