In Board of Mgrs. of 184 Thompson St. Condominium St. Owner LLC, 106 A.D. 3d 542 [1st Dept 2013], the First Department held, "The motion court correctly determined that Non-sponsors may not be held individually liable for any of plaintiff's claims premised solely on alleged violations of the offering plan and certification"("The statements made by defendants in the certification and the plan were mandated by the Martin Act, and plaintiff does not posit any basis of liability outside of that statute, nor assert that the Non-Sponsors are liable under an alter-ego or other veil-piercing theory.")