On September 27th, the Federal District Court for the Northern District of Illinois dismissed plaintiff's securities fraud claims for failing to plead the purchase or sale of a security. The Court applied Seventh Circuit precedent which strictly adheres to the horizontal test for determining whether the "common enterprise" prong of the Howey test is satisfied. Alternatively, the Court dismissed for failing to adequately plead scienter. Zang v. Alliance Financial Services of Illinois, Ltd.