45.  The members of the Class are so numerous that joinder of all members is  impracticable.  While the exact number of Class members is unknown to Plaintiff at this time and  can only be ascertained through appropriate discovery, Plaintiff believes that there are at least  thousands of members in the proposed Class.  Record owners and other members of the Class may  be identified from records maintained by Loma Negra or its transfer agent and may be notified of  the pendency of this action by mail, using the form of notice similar to that customarily used in  securities class actions.   46.  Plaintiff’s claims are typical of the claims of the members of the Class, as all  members of the Class are similarly affected by Defendants’ wrongful conduct in violation of  federal law that is complained of herein.   47.  Plaintiff will fairly and adequately protect the interests of the members of the Class  and has retained counsel competent and experienced in class and securities litigation.   48.  Common questions of law and fact exist as to all members of the Class and  predominate over any questions solely affecting individual members of the Class.  Among the  questions of law and fact common to the Class are:  (a)  whether Defendants violated the Securities Act;  (b)  whether the Registration Statement contained false or misleading  statements of material fact and omitted material information required to be stated therein; and  (c)  to what extent the members of the Class have sustained damages and the  proper measure of damages.   50.  Plaintiff incorporates all the foregoing by reference.   51.  This Cause of Action is brought pursuant to § 11 of the Securities Act, 15 U.S.C. §  77k, on behalf of the Class, against all Defendants.   52.  The Registration Statement contained untrue statements of material facts, omitted  to state other facts necessary to make the statements made not misleading, and omitted to state  material facts required to be stated therein.   53.  Defendants are strictly liable to Plaintiff and the Class for the misstatements and  omissions.   54.  None of the Defendants named herein made a reasonable investigation or possessed  reasonable grounds for the belief that the statements contained in the Registration Statement were  true and without omissions of any material facts and were not misleading.   55.  By reason of the conduct herein alleged, each Defendant violated or controlled a  person who violated § 11 of the Securities Act.   56.  Plaintiff acquired Loma Negra ADS pursuant to the Registration Statement.   57.  Plaintiff and the Class have sustained damages.  The value of Loma Negra ADS  has declined substantially subsequent to and due to Defendants’ violations.   59.  Plaintiff incorporates all the foregoing by reference.   60.  By means of the defective Prospectus, Defendants promoted, solicited, and sold  Loma Negra shares to Plaintiff and other members of the Class.   61.  The prospectus for the IPO contained untrue statements of material fact, and  concealed and failed to disclose material facts, as detailed above.  Defendants owed Plaintiff and  the other members of the Class who purchased Loma Negra shares pursuant to the prospectus the  duty to make a reasonable and diligent investigation of the statements contained in the Prospectus  to ensure that such statements were true and that there was no omission to state a material fact  required to be stated in order to make the statements contained therein not misleading.  Defendants,  in the exercise of reasonable care, should have known of the misstatements and omissions  contained in the prospectus as set forth above.   62.  Plaintiff did not know, nor in the exercise of reasonable diligence could Plaintiff  have known, of the untruths and omissions contained in the prospectus at the time Plaintiff  acquired Loma Negra shares.   64.  Plaintiff incorporates all the foregoing by reference.   65.  This Cause of Action is brought pursuant to § 15 of the Securities Act against all  Defendants.   66.  The Individual Defendants were controlling persons of Loma Negra by virtue of  their positions as directors or senior officers of Loma Negra.  The Individual Defendants each had  a series of direct and indirect business and personal relationships with other directors and officers  and major shareholders of Loma Negra.  The Selling Shareholder controlled the Company.  The  Company controlled the Individual Defendants and all of Loma Negra’s employees.   67.  Loma Negra, the Selling Shareholder, and the Individual Defendants were culpable  participants in the violations of §§ 11 and 12(a)(2) of the Securities Act alleged in the First and  Second Causes of Action above, based on their having signed or authorized the signing of the  Registration Statement and having otherwise participated in the process which allowed the IPO to  be successfully completed.  For Violation of § 11 of the Securities Act  Against All Defendants    For Violation of § 12(a)(2) of the Securities Act  Against All Defendants   For Violation of § 15 of the Securities Act  Against All Defendants   