Last May, I wrote about U.S. District Court Judge Arthur D. Spatt's ruling in Hatteras Enters. v. Forsythe Cosmetic Grp., Ltd., 2018 U.S. Dist. LEXIS 68792.  That post concerned Judge Spatt's decision to apply California's Corporate Securities Law of 1968 in lieu of New York's Martin Act.  In ruling to dismiss a claim based on Section 25401 of the California Corporations Code, Judge Spatt found: 

"The Court need not address whether California law requires privity, because the Plaintiffs' statutory claims for fraud fail for the same reasons as their common law fraud claims. They have failed to identify which Defendants made which statements, and when and where those statements were made."