55.  Plaintiff brings this action as a class action on behalf of all who purchased or  otherwise acquired ADT common stock pursuant or traceable to the Registration Statement issued  in connection with the IPO (the “Class”).  Excluded from the Class are Defendants and their  families, the officers and directors and affiliates of Defendants, 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.   57.  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.   58.  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.   59.  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;   (c)  whether the prices of ADT securities were artificially inflated because of  the Defendants’ conduct complained of herein; and  (d)  to what extent the members of the Class have sustained damages and the  proper measure of damages.   60.  A class action is superior to all other available methods for the fair and efficient  adjudication of this controversy since joinder of all members is impracticable.  Furthermore, as the  damages suffered by individual Class members may be relatively small, the expense and burden  of individual litigation make it impossible for members of the Class to individually redress the  wrongs done to them.  There will be no difficulty in the management of this action as a class action.  61.  Plaintiff incorporates all the foregoing by reference.   63.  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.   64.  Defendants are strictly liable to Plaintiff and the Class for the misstatements and  omissions.   65.  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.   66.  By reason of the conduct herein alleged, each Defendant violated or controlled a  person who violated §11 of the Securities Act.   67.  Plaintiff acquired ADT shares pursuant to the Registration Statement.   68.  Plaintiff and the Class have sustained damages.  The value of ADT common stock  has declined substantially subsequent to and due to Defendants’ violations.   69.  At the time of their purchases of ADT shares, Plaintiff and other members of the  Class were without knowledge of the facts concerning the wrongful conduct alleged herein and  could not have reasonably discovered those facts prior to the disclosures herein.  Less than one  year has elapsed from the time that Plaintiff discovered or reasonably could have discovered the  facts upon which this Complaint is based to the time that Plaintiff commenced this action.  Less  than three years has elapsed between the time that the securities upon which this Cause of Action  is brought were offered to the public and the time Plaintiff commenced this action.  70.  Plaintiff incorporates all the foregoing by reference.   71.  By means of the defective Prospectus, Defendants promoted, solicited, and sold  ADT shares to Plaintiff and other members of the Class.   73.  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 ADT shares.   74.  By reason of the conduct alleged herein, Defendants violated §12(a)(2) of the  Securities Act.  As a direct and proximate result of such violations, Plaintiff and the other members  of the Class who purchased ADT shares pursuant to the prospectus sustained substantial damages  in connection with their purchases of the stock.  Accordingly, Plaintiff and the other members of  the Class who hold the common stock issued pursuant to the Prospectus have the right to rescind  and recover the consideration paid for their shares, and hereby tender their common stock to  Defendants sued herein.  Class members who have sold their common stock seek damages to the  extent permitted by law.  75.  Plaintiff incorporates all the foregoing by reference.   76.  This Cause of Action is brought pursuant to §15 of the Securities Act against all  Defendants.   78.  ADT, Apollo Global, 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 Except Apollo Global    For Violation of §15 of the Securities Act  Against All Defendants   For Violation of §12(a)(2) of the Securities Act  Against All Defendants  