As a result of Defendants’ misleading statements, Plaintiff and other members of the Class have suffered significant damages.
JURISDICTION AND VENUE
The claims alleged herein arise under Sections 12(a)(2) and 15 of the SecuritiesAct of 1933 (the “Securities Act”), 15 U.S.C. §§ 77l(a)(2) and 77o, and the rules and regulationsof the Securities and Exchange Commission (“SEC”) promulgated thereunder.6.
This Court has jurisdiction over the subject matter of this action pursuant toSection 22(a) of the Securities Act, 15 U.S.C. § 77v(a).7.
Venue is proper in this District pursuant to Section 22(a) of the Securities Act, 15U.S.C. § 77v(a) and 28 U.S.C. § 1391(d).8.
In connection with the acts alleged in this complaint, Defendants, directly or indirectly, used the means and instrumentalities of interstate commerce, including, but notlimited to, the United States mails, interstate electronic communications, interstate telephonecommunications and the facilities of the national securities markets.
Plaintiff Brockton Retirement Board is a public retirement system representingcurrent and former employees of the City of Brockton, Massachusetts. Brockton invested in theOGR Fund as set forth in the accompanying certification, incorporated by reference herein, andhas been damaged thereby. Defendants solicited Brockton to make its investment in the OGR Fund in the Commonwealth of Massachusetts.10.
Defendant OGR Fund is a Delaware limited partnership with its principal place of business located in New York, New York.