Plaintiffs motion to recertify the Class and add a sub-class
Courts in this District have consistently affirmed that both Securities Act and Exchange Act claims are especially well-suited to class-wide adjudication.5 For this reason, the Court is respectfully requested to certify the following class and subclasses: A Section 10(b) class against the Underwriters consisting of: All purchasers of Puda common stock and call options on Puda common stock and sellers of put options on Puda common stock during the period commencing December 8, 2010, through the market close on April 7, 2011 (the “Class Period”), and who were damaged thereby; A Section 11 subclass against Puda, Zhao, the Underwriters and the Directors consisting of: All purchasers of Puda common stock pursuant or traceable to the public offering of Puda shares on or about December 8, 2010, and who were damaged thereby; and A Section 12 subclass against Puda and the Underwriters consisting of: All purchasers of Puda common stock directly from the underwriters in the December 8, 2010, public offering or whose purchase of shares registered in such offering was solicited by Puda and/or the Underwriters for its financial interest, and who were damaged thereby.6 As set forth more fully herein, class certification and movants’ appointment as Class Representatives are both warranted. Plaintiffs also seek that Glancy Binkow & Goldberg LLP