Core Viewpoint - The article discusses the differences between U.S. and Canadian securities class action laws, particularly focusing on jurisdictional approaches and the implications for investors seeking recovery for losses. Group 1: U.S. Securities Class Actions - U.S. federal securities law limits recovery to transactions involving shares purchased on U.S. exchanges, creating a narrow access to U.S. courts for investors [1][2] - The Supreme Court's ruling in Morrison v. National Australia Bank established a transaction-based limit, restricting claims to U.S.-exchange purchases and domestic transactions [2][3] - Investors holding cross-listed stocks purchased on both U.S. and non-U.S. exchanges may face challenges in seeking full recovery in U.S. courts [3] Group 2: Canadian Securities Class Actions - Ontario courts reject the U.S. exchange-based rule, focusing instead on a "real and substantial connection" to the province for jurisdiction in securities class actions [4] - If a real and substantial connection exists, investors can seek full recovery in Canada for shares purchased on both Canadian and foreign exchanges [5] - Ontario courts are willing to certify classes that include foreign-exchange purchasers when there is a close connection to the issuer and the dispute [6] Group 3: Long-Arm Jurisdiction in Ontario - Ontario's long-arm jurisdiction allows courts to hear claims related to shares purchased on non-Canadian exchanges if there is a significant connection to Ontario [8] - The case of Abdula v. Canadian Solar confirmed that a foreign-listed issuer can face a Canadian class action if it has a meaningful connection to Canada [9] - The court in Kamrani-Ghadjar v. Anaergia ruled that the nationality of the underwriter does not limit the scope of claims in IPO misrepresentation cases [10][11] Group 4: Implications for Investors - Investment advisors must consider the implications of multiple jurisdictions for clients with concentrated positions in companies involved in class actions [11] - Portfolio managers and institutional investors may need to develop litigation participation policies to navigate claims across different jurisdictions [12] - Key takeaways highlight that Canadian jurisdiction is connection-driven, foreign-exchange purchasers can be liable, and foreign underwriters may also face claims in Canada [13]