(Violations of Section 20(a) of the Exchange Act Against The Individual Defendants)   17.  On March 31, 2014, after the market closed, the Company filed a Form 40 F for the  fiscal year ended December 31, 2013 (the “2013 40-F”) with the SEC, which provided the  Company’s year-end financial results and position and stated that the Company’s internal control  over financial reporting and disclosure controls and procedures were effective as of December 31,  2013. The 2013 40-F was signed by Defendant Jeannes. The 2013 40-F also contained signed  certifications pursuant to the Sarbanes-Oxley Act of 2002 (“SOX”) by Defendants Jeannes and  Hall attesting to the accuracy of financial reporting, the disclosure of any material changes to the  Company’s internal controls over financial reporting, and the disclosure of all fraud.   19.  Goldcorp’s Management’s Discussion and Analysis of Financial Condition and  Results of Operations for the year ended December 31, 2013, attached as Exhibit 99.2 to the 2013  40-F, provided updates on the water wells near the Peñasquito Mine, stating in pertinent part:  Peñasquito continued to incrementally increase its fresh water production in 2013  from 69,500 to 77,000 cubic metres per day with the addition of eight new wells in  the Torres-Vergel area and four new wells in the mine area. These new wells not  only supplied water to replace the declining production in the existing well field,  but allowed water production to increase above 2012 year end levels. This increase  in water production combined with rigorous control of tailings management and  improved efficiencies in the primary crusher and augmented feed circuit, allowed  an increase in plant throughput from 99,945 tonnes per day in 2012 to 106,200  tonnes per day in 2013.  * * *  Failure to comply strictly with applicable laws, regulations and local practices  relating to mineral right applications and tenure, could result in loss, reduction or  expropriation of entitlements, or the imposition of additional local or foreign parties  as joint venture partners with carried or other interests. The occurrence of these  various factors and uncertainties cannot be accurately predicted and could have a  material adverse effect on the Company’s operations or profitability.   23.  On March 30, 2016, the Company filed a Form 40-F for the fiscal year ended  December 31, 2015 (the “2015 40-F”) with the SEC, which provided the Company’s year-end  financial results and position and stated that the Company’s internal control over financial  reporting and disclosure controls and procedures were effective as of December 31, 2015. The  2015 40-F was signed by Defendant Garofalo. The 2015 40-F also contained signed SOX  certifications by Defendants Garofalo and Ball attesting to the accuracy of financial reporting, the  disclosure of any material to the Company’s internal controls over financial reporting, and the  disclosure of all fraud.   27.   30.  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 those who purchased or otherwise  acquired Goldcorp securities during the Class Period (the “Class”); and were damaged upon the  revelation of the alleged corrective disclosures.  Excluded from the Class are Defendants herein,  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.   32.  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.   33.  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.  Plaintiff has  no interests antagonistic to or in conflict with those of the Class.   34.  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:      whether the federal securities laws were violated by Defendants’ acts as alleged  herein;    whether statements made by Defendants to the investing public during the Class  Period misrepresented material facts about the financial condition, business,  operations, and management of Goldcorp;    whether Defendants’ public statements to the investing public during the Class  Period omitted material facts necessary to make the statements made, in light of the  circumstances under which they were made, not misleading;    whether the Individual Defendants caused Goldcorp to issue false and misleading  SEC filings and public statements during the Class Period;    whether Defendants acted knowingly or recklessly in issuing false and misleading  SEC filings and public statements during the Class Period;    whether the prices of Goldcorp common shares during the Class Period were  artificially inflated because of the Defendants’ conduct complained of herein; and    whether the members of the Class have sustained damages and, if so, what is the  proper measure of damages.   36.  Plaintiff will rely, in part, upon the presumption of reliance established by the fraud- on-the-market doctrine in that:    Defendants made public misrepresentations or failed to disclose material facts  during the Class Period;    the omissions and misrepresentations were material;    Goldcorp securities are traded in an efficient market;    the Company’s shares were liquid and traded with moderate to heavy volume  during the Class Period;    the Company traded on the NYSE and was covered by multiple analysts;    the misrepresentations and omissions alleged would tend to induce a reasonable  investor to misjudge the value of the Company’s securities; and    Plaintiff and members of the Class purchased, acquired and/or sold Goldcorp  securities between the time the Defendants failed to disclose or misrepresented  material facts and the time the true facts were disclosed, without knowledge of  the omitted or misrepresented facts.   37.  Based upon the foregoing, Plaintiff and the members of the Class are entitled to a  presumption of reliance upon the integrity of the market.    39.  Plaintiff repeats and realleges each and every allegation contained above as if fully  set forth herein.   40.  This Count is asserted against Goldcorp and the Individual Defendants and is based  upon Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5 promulgated  thereunder by the SEC.   41.  During the Class Period, Goldcorp and the Individual Defendants, individually and  in concert, directly or indirectly, disseminated or approved the false statements specified above,  which they knew or deliberately disregarded were misleading in that they contained  misrepresentations and failed to disclose material facts necessary in order to make the statements  made, in light of the circumstances under which they were made, not misleading.   42.  Goldcorp and the Individual Defendants violated §10(b) of the 1934 Act and Rule  10b-5 in that they:    employed devices, schemes and artifices to defraud;    made untrue statements of material facts or omitted to state material facts necessary  in order to make the statements made, in light of the circumstances under which  they were made, not misleading; or    engaged in acts, practices and a course of business that operated as a fraud or deceit  upon plaintiff and others similarly situated in connection with their purchases of  Goldcorp common shares during the Class Period.   44.  Individual Defendants, who are the senior officers and/or directors of the Company,  had actual knowledge of the material omissions and/or the falsity of the material statements set  forth above, and intended to deceive Plaintiff and the other members of the Class, or, in the  alternative, acted with reckless disregard for the truth when they failed to ascertain and disclose  the true facts in the statements made by them or other Goldcorp personnel to members of the  investing public, including Plaintiff and the Class.   45.  As a result of the foregoing, the market price of Goldcorp common shares was  artificially inflated during the Class Period. In ignorance of the falsity of Goldcorp’s and the  Individual Defendants’ statements, Plaintiff and the other members of the Class relied on the  statements described above and/or the integrity of the market price of Goldcorp common shares  during the Class Period in purchasing Goldcorp common shares at prices that were artificially  inflated as a result of Goldcorp’s and the Individual Defendants’ false and misleading statements.   47.  As a result of the wrongful conduct alleged herein, Plaintiff and other members of  the Class have suffered damages in an amount to be established at trial.   48.  By reason of the foregoing, Goldcorp and the Individual Defendants have violated  Section 10(b) of the 1934 Act and Rule 10b-5 promulgated thereunder and are liable to the plaintiff  and the other members of the Class for substantial damages which they suffered in connection with  their purchase of Goldcorp common shares during the Class Period.  49.  Plaintiff repeats and realleges each and every allegation contained in the foregoing  paragraphs as if fully set forth herein.   50.  During the Class Period, the Individual Defendants participated in the operation  and management of Goldcorp, and conducted and participated, directly and indirectly, in the  conduct of Goldcorp’s business affairs. Because of their senior positions, they knew the adverse  non-public information regarding Goldcorp’s business practices.   51.  As officers and/or directors of a publicly owned company, the Individual  Defendants had a duty to disseminate accurate and truthful information with respect to Goldcorp’s  financial condition and results of operations, and to correct promptly any public statements issued  by Goldcorp which had become materially false or misleading.   53.  Each of the Individual Defendants, therefore, acted as a controlling person of  Goldcorp. By reason of their senior management positions and/or being directors of Goldcorp,  each of the Individual Defendants had the power to direct the actions of, and exercised the same  to cause, Goldcorp to engage in the unlawful acts and conduct complained of herein. Each of the  Individual Defendants exercised control over the general operations of Goldcorp and possessed  the power to control the specific activities which comprise the primary violations about which  Plaintiff and the other members of the Class complain.   54.  By reason of the above conduct, the Individual Defendants are liable pursuant to  Section 20(a) of the Exchange Act for the violations committed by Goldcorp.  Background   Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Promulgated Thereunder  Against All Defendants  