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Some recent investigations have alleged that analysts of certain securities, many of them internet stocks, were motivated to write positive reports at least in part to help their investment banking divisions win deals and to help their trading departments maintain the prices of those stocks in their inventories. Those investigations also have alleged that customers of third‐party firms relied on those reports to make investment decisions, further fueling the market. These customers, however, face significant hurdles to recovery from firms that issued such reports.

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