40.  This is a class action on behalf of all purchasers of Avon common stock during the  Class Period (the “Class”).  Excluded from the Class are defendants and their families, 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.   41.  Common questions of law and fact predominate and include: (a) whether defendants  violated the Exchange Act; (b) whether defendants omitted and/or misrepresented material facts;  (c) whether defendants knew or recklessly disregarded that their statements were false; (d) whether  defendants manipulated the market price of Avon common stock; (e) whether the price of Avon  common stock was artificially inflated during the Class Period; and (f) the extent of and appropriate  measure of damages.   43.  Plaintiff repeats and realleges the above paragraphs as though fully set forth herein.   44.  During the Class Period, defendants carried out a plan that was intended to, and did:  (a) deceive the investing public, including plaintiff and the Class; and (b) artificially manipulate the  price of Avon common stock.   45.  Defendants: (a) employed devices, schemes and artifices to defraud; (b) made untrue  statements of material fact and/or omitted to state material facts necessary to make the statements  made not misleading; and (c) engaged in acts, practices and a course of conduct that operated as a  fraud and deceit upon purchasers of Avon common stock in violation of §10(b) of the Exchange Act  and Rule 10b-5.  Defendants are sued as primary participants in the wrongful and illegal conduct  charged herein.   46.  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 the adverse material information as specified herein.   47.  Defendants’ liability arises from the fact that they developed and engaged in a scheme  to manipulate the price of Avon common stock and were aware of the dissemination of information  to the investing public that they knew or recklessly disregarded was materially false and misleading.     49.  By virtue of the foregoing, defendants have violated §10(b) of the Exchange Act, and  Rule 10b-5 promulgated thereunder.   50.  As a direct and proximate result of defendants’ wrongful conduct, plaintiff and  members of the Class suffered damages in connection with their respective purchases and sales of  Avon common stock during the Class Period.  51.  Plaintiff repeats and realleges the above paragraphs as though fully set forth herein.   52.  The Individual  Defendants had control over Avon and made the materially false and  misleading statements and omissions on behalf of Avon within the meaning of §20(a) of the  Exchange Act as alleged herein.  By virtue of their executive positions, and their culpable  participation, as alleged above, the Individual Defendants had the power to influence and control and  did, directly or indirectly, influence and control the decision making of the Company, including the  content and dissemination of the various statements that plaintiff contends were false and  misleading.  The Individual Defendants were provided with or had unlimited access to the  Company’s internal reports, press releases, public filings and other statements alleged by plaintiff to  be misleading prior to or shortly after these statements were issued, and had the ability to prevent the  issuance of the statements or cause them to be corrected.   54.  By reason of such wrongful conduct, defendants are liable pursuant to §20(a) of the  Exchange Act.  As a direct and proximate result of defendants’ wrongful conduct, plaintiff and the  other members of the Class suffered damages in connection with their purchases of the Company’s  common stock during the Class Period.  For Violation of §20(a) of the Exchange Act  Against All Defendants   For Violation of §10(b) of the Exchange Act  and Rule 10b-5 Against All Defendants  