The Individual Defendants acted as controlling persons of China Aviation within the
meaning of §20(a) of the 1934 Act. By reason of their positions as officers and/or directors of China
Aviation, and their ownership of China Aviation stock, the Individual Defendants had the power and
authority to cause China Aviation to engage in the wrongful conduct complained of herein and did
exercise such control. By reason of such conduct, the Individual Defendants and China Aviation are
liable pursuant to §20(a) of the 1934 Act.