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61. Plaintiff will adequately protect the interests of the Class and has retained counsel who are experienced in class action securities litigation. Plaintiff has no interests which conflict with those of the Class. 62. A class action is superior to other available methods for the fair and efficient adjudication of this controversy. LOSS CAUSATION/ECONOMIC LOSS 63. Defendants' wrongful conduct, as alleged herein, directly and proximately caused the economic loss suffered by Plaintiff and the Class. The price of Ormat's securities significantly declined when the misrepresentations made to the market, and/or the information alleged herein to have been concealed from the market, and/or the effects thereof, were revealed, causing investors' losses. As a result of their purchases/acquisition of Ormat securities during the Class Period, plaintiff and other members of the Class suffered economic loss, i.e., damages, under the federal securities laws. SCIENTER ALLEGATIONS 64. During the Class Period, defendants had both the motive and opportunity to conduct fraud. They also had actual knowledge of the misleading nature of the statements they made or acted in reckless disregard of the true information known to them at the time. In so doing, defendants participated in a scheme to defraud and committed acts, practices and participated in a course of business that operated as a fraud or deceit on purchasers of Ormat's securities during the Class Period. 65. Additionally, during the Class Period, and with the Company's securities trading at artificially inflated prices, defendants completed a public equity offering, as detailed at ΒΆ 29, raising gross proceeds of over $153 million, and Company insiders collectively sold 66,427 23PDF Image | ORMAT TECHNOLOGIES Lawsuit
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