304. Plaintiffs on behalf of themselves, their ancestors and all other descendants who are similarly situated, re-allege, as if fully set forth, each and every allegation contained in the preceding paragraphs.

305. Defendants' predecessor companies aided or abetted, or under other theories of secondary liability as have been described more fully herein, participated in, allowed, or implicitly or recklessly, sanctioned, and/or benefited from an institution that relied in the sexual exploitation, violent abuse and rape to achieve its goals of a malleable and unpaid work force. The violence and crimes against the enslaved group were done with the calculated intent of demeaning, subjugating, and controlling the enslaved population for purposes of exploitation for profit and for the direct benefit of commercial industries. This wholesale sexual exploitation resulted in the birth of countless racially mixed children who remained unclaimed by their fathers. It further resulted in and was intended to result in the creation of a belief structure founded on racial ideology based upon inequality.

306. Likewise, the defendants' predecessor companies aided or abetted or, under other theories of secondary liability, as have been described more fully herein, participated in, allowed, implicitly or recklessly, and/or benefited unjustly from human breeding whereby slave owners forced plaintiffs and plaintiffs' ancestors to have sex with multiple individuals in order to create a stronger, bigger and healthier enslaved person for exploitation for profit. The result of this was to demean and diminish the humanity of plaintiffs. African-Americans are still subject to the false legacies and harmful myths that grew out of this inhumane practice.

307. Defendants' predecessor companies aided or abetted, participated in, allowed, implicitly and/or recklessly sanctioned, and/or unjustly benefited from the wholesale torture of enslaved people. Abuse was used as mechanism to intimidate, control, and terrorize plaintiffs in order to prevent any resistance. Such torture also served to ingrain in the minds of plaintiff and plaintiffs' ancestors the belief of the omnipotence of the slave master. The torture was intended to have a long lasting impact on plaintiff, plaintiffs' ancestors and the rest of society. Acts of torture were usually public and intended to inflict significant fear among the enslaved and confidence by those in power that such treatment was legitimate.

308. The perpetuation of these false beliefs were done with the purpose to enslave plaintiffs and plaintiffs' ancestors for profits; in order to force the social death of plaintiff and plaintiffs' ancestors; in order to transform plaintiffs and plaintiffs' ancestors into a commodity to be worked, sold, and discarded without resistance with the intent to cause or with reckless disregard of a substantial probability of causing severe emotional harm and distress of such intensity that no person could be expected to endure.

309. This behavior resulted also in contagion and mass belief that plaintiffs and plaintiffs' ancestors were beasts, marginal, of inferior intellect, incapable of reason and logic, diseased, inhuman, unequal to whites, descendants of the devil, destined by God to be slaves to defendants and, incapable of being civilized. The result of this initial effort caused severe emotional harm and distress.

310. As a result of defendants' wrongful acts and omissions, plaintiffs and the plaintiff class have been injured and demand monetary judgment against the defendants jointly, severally and/or in the alternative demand: (a) an accounting of the slave labor monies, profits and/or benefits derived by defendants; (b) a constructive trust in the value of said monies, profits and/or benefits derived by defendants' use of slave labor; (c) full restitution in the value of all monies, profits, and/or benefits derived by defendants' use of slave labor; (d) equitable disgorgement of all said monies, profits, and/or benefits derived by defendants' exploitation of slave labor; and (e) other damages in an amount in excess of the jurisdictional limits of this Court. Plaintiffs further demand punitive damages to punish these defendants and deter others from committing the types of action herein described.