(S.C.J.) and Carom v. Bre-X Minerals Ltd. (1998), 41 O.R. (3d)
780,  O.J. No. 4496 (Gen. Div.) for the proposition that
a causal link is required and reliance cannot be presumed.
 We disagree.
 The pleadings in the present case allege, in effect, that
( i) the defendants conspired to unduly lessen competition and
enhance the prices of LIBs and LIB products, contrary to
Part VI of the Competition Act;
( ii) the conspiracy was directed towards the proposed class
members and the defendants knew it was likely to cause injury
to the proposed class members, rendering the defendants
liable for the tort of civil conspiracy;
( iii) LIB and LIB product prices were fixed at artificially inflated
levels as a result of the conspiracy;
( iv) members of the proposed class paid more for LIBs and LIB
products than they would have, absent the conspiracy.
 Although the pleading is somewhat lacking in particulars,
specifically with respect to the claim that umbrella purchasers
were harmed by the conspiracy, a generous approach must be
taken when assessing the adequacy of the pleadings at this stage:
Imperial Tobacco, at para. 21.
 Though umbrella purchasers are not explicitly mentioned,
they did not need to be. The allegation of damage at para. 76(c) of
the statement of claim is broad enough to encompass the harm
caused to umbrella purchasers. That paragraph reads as follows:
76. The Plaintiffs and other members of the proposed class have suffered
damages as a result of the conspiracy alleged herein. The Defendants’
conspiracy had the following effects, among others: . . .
(c) the Plaintiffs and other members of the proposed class paid more
for lithium batteries and lithium battery products than they would
have paid in the absence of the conspiracy.
 Reading the statement of claim as a whole, it is clear that
the appellants allege that non-defendant manufacturers and suppliers raised their prices as result of the defendants’ conspiracy.
In our view, that is sufficient for the purpose of certification and
it is not fatal that the pleading does not expressly link the effects
of the conspiracy to the pricing decisions of non-defendants.
 Finally, the respondents’ reliance on case law in the
securities class action context, in which courts have rejected the
presumption of reliance created by the “fraud on the market”
theory, is, in our view, misplaced. These cases have no application