41.  Plains is a publicly-traded master limited partnership, or MLP, involved  in interstate and intrastate crude oil pipeline transportation and crude oil storage  activities that has grown into one of North America’s largest energy pipeline  operators.  That growth has been achieved through a two-decade acquisition binge  during which Plains acquired significant pipelines and terminal systems – many of  them aging and in need of significant repair – in California, Texas and Canada,  among other places.     97.  As alleged herein, the Company, Plains Holdings, and the Officer  Defendants knew that the public documents and statements issued or disseminated  in the name of the Company were materially false and misleading; knew that such  statements or documents would be issued or disseminated to the investing public;  and knowingly and substantially participated in or acquiesced in the issuance or  dissemination of such statements or documents as primary violations of the federal  securities laws.  As set forth elsewhere herein in detail, the Company, Plains  Holdings, and the Officer Defendants, by virtue of their receipt of information  reflecting the true facts regarding Plains, their control over, and receipt or  modification of Plains allegedly materially misleading statements, and their  associations with the Company which made them privy to confidential proprietary  information concerning Plains, participated in the fraudulent scheme alleged herein.  All Defendants ............................................................................................... 41  COUNT IV Violations Of Section 12(a)(2) Of The Securities Act  Against The Underwriter Defendants ............................................................ 42  COUNT I Violations Of Section 10(b) Of The Exchange Act And   Rule 10b-5 Against Plains, Plains Holdings And The Officer  Defendants ..................................................................................................... 39  The Officer Defendants And The Director Defendants ................................ 43  XI.  PRAYER FOR RELIEF ................................................................................ 44  V.  DEFENDANTS’ FALSE AND MISLEADING   STATEMENTS AND OMISSIONS OF MATERIAL FACTS ................... 15  A.  Line 901 Ruptures, Causing Extensive Damage To The  Santa Barbara Coastline ...................................................................... 30  B.  Plains Senior Executives Conceal The True Extent And  Scope Of The Spill .............................................................................. 31  C.  Regulatory And Congressional Investigations Reveal  Further Information Concerning Plains’ Defective  Pipeline Maintenance, Monitoring And Spill Response ..................... 32  D.  Plains Reveals The Line 901 Spill Was Far More Severe  Than Reported ..................................................................................... 33  VI.  VII.  PRESUMPTION OF RELIANCE: FRAUD ON THE  MARKET DOCTRINE ................................................................................. 34  VIII.  LOSS CAUSATION/ECONOMIC LOSS .................................................... 35  IX. 