for such security with interest thereon, less the amount of any income received thereon, ... or for damages if he no longer owns the security,” 15 U.S.C. § 77l (a), there can be no recovery unless the purchaser has suffered a loss. In re Broderbund/Learning Co. Sec. Litig., 294 F.3d 1201, 1205 (9th Cir.2002). “That is to say, what the purchaser is entitled to is ‘a return of the consideration paid, reduced by the amount realized when he sold the security and by any “income received” on the security.’ ” Id. (citing Randall v. Loftsgaarden, 478 U.S. 647, 656, 106 S.Ct. 3143, 92 L.Ed.2d 525 (1986) (citation omitted)). Causation, however, is not a necessary element of a prima facie case under section 12 of the Securities Act. See Casella v. Webb, 883 F.2d 805, 808 & n. 8 (9th Cir.1989) (<HOLDING>). The district court failed to reach the issue
holding that the alleged misrepresentations concerning the transaction fees charged by a broker did not concern the value of a security or the consideration received holding that termite damage does not fall within the meaning of property damage in the policy because the alleged misrepresentations did not cause the damage the termites did holding that a plaintiff satisfied rule 9b by pleading which machines were the subject of alleged fraudulent transactions and the nature and subject of the alleged misrepresentations holding that if the alleged misrepresentations are material a plaintiff is entitled to recovery whether or not the misrepresentations caused the alleged damage holding that a principal does not have an action against his agent for indemnification based on the agents misrepresentations because the principal was not blameless in the misrepresentations made to the third parties