What is the test for dismissing a pro se complaint alleging that the market had lost value on the basis of false representation?

MultiRegion, United States of America

The following excerpt is from Zerman v. Ball, 735 F.2d 15 (2nd Cir. 1984):

In sum, even construing this pro se complaint liberally, see Haines v. Kerner, 404 U.S. 519, 520, 92 S.Ct. 594, 595, 30 L.Ed.2d 652 (1972), we conclude that insofar as the complaint was based on items (a) and (c)-(h), it was properly dismissed pursuant to Rule 12(b)(6).

Page 22

2. The representation that the market was up

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