18.  Just Energy purports to be a consumer company focused on essential needs,  including electricity and natural gas commodities; on health and well-being, through products  such as water quality and filtration devices; and on utility conservation, including renewable  energy options.  Materially False and Misleading  Statements Issued During the Class Period   19.  The Class Period begins on November 9, 2017.  On that day, the Company  reported its quarterly results for the period ended September 30, 2017 in a Form 6-K filed with  the SEC. Regarding internal control over financial reporting, the Company stated, in relevant  part:  As of September 30, 2017, the Co-Chief Executive Officers (“Co-CEOs”) and  Chief Financial Officer (“CFO”) of the Company, along with the assistance of  senior management, have designed disclosure controls and procedures to provide  reasonable assurance that material information relating to Just Energy is made  known to the Co-CEOs and CFO, and have designed internal controls over  financial reporting based on the criteria established in the 2013 Internal Control –  Integrated Framework issued by the Committee of Sponsoring Organizations of  the Treadway Commission (the COSO criteria) to provide reasonable assurance  regarding the reliability of financial reporting and the preparation of consolidated  financial statements in accordance with IFRS.   During the three and six months ended September 30, 2017, there were no  changes in Just Energy’s internal controls over financial reporting that occurred  that have significantly affected, or are reasonably likely to significantly affect, the  Company’s internal controls over financial reporting.   32.  Plaintiff brings this action as a class action pursuant to Federal Rule of Civil  Procedure 23(a) and (b)(3) on behalf of a class, consisting of all persons and entities that  acquired Just Energy securities between November 9, 2017 and July 23, 2019, inclusive, and  who were damaged thereby (the “Class”). Excluded from the Class are Defendants, the officers  and directors of the Company, at all relevant times, members of their immediate families and  their legal representatives, heirs, successors, or assigns, and any entity in which Defendants have  or had a controlling interest.   38.  The market for Just Energy’s securities was open, well-developed and efficient at  all relevant times.  As a result of these materially false and/or misleading statements, and/or  failures to disclose, Just Energy’s securities traded at artificially inflated prices during the Class  Period.  Plaintiff and other members of the Class purchased or otherwise acquired Just Energy’s  securities relying upon the integrity of the market price of the Company’s securities and market  information relating to Just Energy, and have been damaged thereby.   39.  During the Class Period, Defendants materially misled the investing public,  thereby inflating the price of Just Energy’s securities, by publicly issuing false and/or misleading  statements and/or omitting to disclose material facts necessary to make Defendants’ statements,  as set forth herein, not false and/or misleading.  The statements and omissions were materially  false and/or misleading because they failed to disclose material adverse information and/or  misrepresented the truth about Just Energy’s business, operations, and prospects as alleged  herein.   43.  As alleged herein, Defendants acted with scienter since Defendants knew that the  public documents and statements issued or disseminated in the name of the Company were  materially false and/or misleading; knew that such statements or documents would be issued or  disseminated to the investing public; and knowingly and substantially participated 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 Individual Defendants, by  virtue of their receipt of information reflecting the true facts regarding Just Energy, their control  over, and/or receipt and/or modification of Just Energy’s allegedly materially misleading  misstatements and/or their associations with the Company which made them privy to  confidential proprietary information concerning Just Energy, participated in the fraudulent  scheme alleged herein.   50.  Plaintiff repeats and re-alleges each and every allegation contained above as if  fully set forth herein.    51.  During the Class Period, Defendants carried out a plan, scheme and course of  conduct which was intended to and, throughout the Class Period, did: (i) deceive the investing  public, including Plaintiff and other Class members, as alleged herein; and (ii) cause Plaintiff and  other members of the Class to purchase Just Energy’s securities at artificially inflated prices.  In  furtherance of this unlawful scheme, plan and course of conduct, Defendants, and each  defendant, took the actions set forth herein.   52.  Defendants (i) employed devices, schemes, and artifices to defraud; (ii) made  untrue statements of material fact and/or omitted to state material facts necessary to make the  statements not misleading; and (iii) engaged in acts, practices, and a course of business which  operated as a fraud and deceit upon the purchasers of the Company’s securities in an effort to  maintain artificially high market prices for Just Energy’s securities in violation of Section 10(b)  of the Exchange Act and Rule 10b-5.  All Defendants are sued either as primary participants in  the wrongful and illegal conduct charged herein or as controlling persons as alleged below.     53.  Defendants, individually and in concert, directly and indirectly, by the use, means  or instrumentalities of interstate commerce and/or of the mails, engaged and participated in a  continuous course of conduct to conceal adverse material information about Just Energy’s  financial well-being and prospects, as specified herein.     61.  Plaintiff repeats and re-alleges each and every allegation contained above as if  fully set forth herein.    Background   Violation of Section 10(b) of The Exchange Act and   Rule 10b-5 Promulgated Thereunder   Against All Defendants   Violation of Section 20(a) of The Exchange Act   Against the Individual Defendants  