The exchanges assert that the foregoing allegations are insufficient because the plaintiffs do not allege that the exchanges themselves engaged in any manipulative “trading activity.” The exchanges do not cite, and we are not aware of, any authority explicitly stating that such a claim must concern a defendant’s trading activity. Instead, § 10(b) and Rule 10b-22 prohibit “all fraudulent schemes in connection with the purchase or sale of securities,” including schemes that consist of manipulative or deceptive “market activity.”
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