demonstrate loss resulting from that intentional wrongdoing,
serves to limit any concerns about overly broad liability. We have
already reviewed those statutory limitations. If the principle of
indeterminate liability does apply in this context, those limitations serve to carefully circumscribe liability. As the court noted
in Godfrey BCCA, at para. 232, and as supported by our previous
analysis: “the tort of civil conspiracy provides even stronger
built-in limitations controlling the scope of liability than those
inherent in the Competition Act”.
 Even though the addition of umbrella purchasers would
increase the plaintiff base and the potential damages to be paid, it
is important not to confuse indeterminate liability with significant
liability: Livent, at para. 43. Certain activities, like conspiring to fix
prices for batteries that are in high demand for contemporary
society, may well come with significant liability. Although the
addition of umbrella claimants would add additional exposure,
that exposure would be in relation to specific products and
limited by a defined class and a defined class period. It would not
be limitless exposure.
 We do not agree with the respondents’ assertion that they
had “no control” over the actions of the non-defendants and so
there is an indeterminacy problem. The Divisional Court
addressed the “no control” point in its reasons. It concluded that
the situation in this case was similar to the situation in Imperial
Tobacco, where the Supreme Court concluded that the prospect of
indeterminate liability was fatal to the tobacco companies’ claims
of negligent misrepresentation against the federal government.
The Supreme Court held that indeterminacy was a problem
because, insofar as the claims were based on representations to
consumers, Canada had no control over the number of people
who smoked light cigarettes: Imperial Tobacco, at para. 99.
 Like Imperial Tobacco, the Divisional Court concluded in
this case that the defendants had “no control over the actions of
non-defendant manufacturers”. In particular, they had no control
over whether the non-defendant manufacturers chose to match
the prices of the defendants and they had no control over the
volume of sales by the non-defendant manufacturers.
 The “no control” argument fails to account for the manner
in which the claim has been pleaded and the very essence of an
umbrella purchaser claim: the umbrella effect.
 As for the manner in which the claim has been pleaded,
the plaintiffs specifically allege that the defendants intentionally
directed their conduct at the proposed class — a class that
includes umbrella purchasers — and knew that their conduct was
likely to cause injury to that class. Taking those pleadings as true,