F.2d 927, 931 (9th Cir.1985) (quoting TSC Industries, Inc. v. Northway, Inc., 426 U.S. 438, 450, 96 S.Ct. 2126, 2133, 48 L.Ed.2d 757 (1976)).
Chalmers argues that her alleged representation that the Casella’s investment in Hondo House was “a sure thing” meets this requirement, for no reasonable person would base an investment on such a statement. The Casellas argue the statement is to be evaluated in context, and in this case was coupled with, and served to emphasize, specific misrepresentations of fact as to the future profitability of Hondo House and the tax benefits that would flow from the investment, which “were unquestionably material.” Anderson, 774 F.2d at 931. We agree. Statements made in the course of an oral presentation “cannot be considered in isolation,” but must be viewed “in the context of the total presentation.” Hughes v. Dempsey-Tegeler & Co., 534 F.2d 156, 176 (9th Cir.1976). What might be innocuous “puffery” or mere statement of opinion standing alone may be actionable as an integral part of a representation of material fact when used to emphasize and induce reliance upon such a representation. G & M, Inc. v. Newbern, 488 F.2d 742, 745-46 (9th Cir.1973).
III.
It was error to grant summary judgment for Chalmers as to the remaining alleged misrepresentations on the ground that the Casellas failed to demonstrate these misrepresentations caused them economic harm.
The district court adopted Chalmers’ argument that parties bringing suit under section 12(2) must prove not only that “the violations in question caused the plaintiff[s] to engage in the transaction,” but also that “the misrepresentations or omissions caused the harm,” Hatrock v. Edward D. Jones & Co., 750 F.2d 767, 773 (9th Cir.1984), and concluded a violation of section 12(2) had not been established because any economic loss the Casellas may have suffered was caused by the bankruptcy of Hondo House rather than the alleged misrepresentations regarding the profitability and tax benefits of the investment.6
The language of Section 12(2) clearly states that whenever a security is sold “by means of” a misstatement or omission, the purchaser may tender the security to the seller and recover the purchase price plus interest, less income, or, if the purchaser no longer owns the security, may recover equivalent rescissory damages. Randall v. Loftsgaarden, 478 U.S. 647, 655-56, 106 S.Ct. 3143, 3148-49, 92 L.Ed.2d 525 (1986).7 If the misrepresentations were material, the Casellas were entitled to restitution whether or not the misrepresentations caused the bankruptcy of Hondo House, or somehow defeated the Casellas’ claim for tax deductions. In Professor Loss’ words, “[t]he buyer need not show any causal connection between the misrepresentation and his damage; indeed, he need not even show that he has been damaged.” L. Loss, Fundamentals of Securities Regulation 873 (1988).8 Section 12(2) “is a broad anti-
6
Chalmers argues that because the IRS has not challenged the Hondo House deduction the court should affirm the judgment on the ground Chalmers’ representation as to IRS approval has not been shown to be false. The misrepresentation the Casellas allege, however, is that before purchasing the investment they were told the IRS had already approved Hondo House as a tax shelter. The lack of a subsequent IRS challenge is irrelevant to whether the IRS had given “pre-approval" to the deduction.
7
As the Supreme Court explained: > Congress chose a rescissory remedy when it enacted § 12(2) in order to deter prospectus fraud and encourage full disclosure as well as to make investors whole. Indeed, by enabling the victims of prospectus fraud to demand rescission upon tender of the security, Congress shifted the risk of an intervening decline in the value of the security to defendants, whether or not that decline was actually caused by the fraud. Thus, rescission adds an additional measure of deterrence as compared to a purely compensatory measure of damages. Randall, 478 U.S. at 659, 106 S.Ct. at 3150 (citations omitted).
8
.The district court and Chalmers mistakenly rely on cases involving Rule 10b-5 rather than § 12(2). Compare In re Financial Corp. of America Shareholder Litig., 796 F.2d 1126, 1130 (9th Cir.1986) (Rule 10b-5 plaintiff must prove not only transaction causation but also loss causation); Bennett v. United States Trust Co., 770 *809F.2d 308, 313 (2d Cir.1985) (same) with Randall, 478 U.S. at 659, 106 S.Ct. at 3150 (section 12(2) plaintiff need not prove loss causation); Wilson v. Ruff a & Hanover, P.C., 872 F.2d 1124, 1126 (2d Cir.1989) (same).