The following excerpt is from Alexander v. Pacific Trans-Ocean Resources Ltd., 1991 ABCA 286 (CanLII):
We may begin with allegations that the plaintiffs were induced to buy or hold their shares because of various kinds of misrepresentations by the defendants. That is not an allegation that the defendants harmed the company or its property, with a consequent drop in the true value of the shares. It is totally different. Those allegations do not suggest any harm to the company or its property; they suggest that the property was simply misdescribed to actual or potential investors, first too favorably, and then too unfavorably. That is not a wrong to the company. A bank suing someone who negligently induced it to lend to a company by overstating the company's assets, could scarcely be met by the rule in Foss v. Harbottle, supra. Nor have suits by those fraudulently induced to buy shares ever been barred by the rule in Foss v. Harbottle.