Is Octopus Management vulnerable to a case under s397 Financial Services and Markets Act 2000?

Interesting claim by "Hocus Pocus" solicitors (declaration: with some of whose "members" I do have history for misuse of firm's client accounts for money laundering when even HSBC wouldn't bank their client) against the investment managers of Home REIT. 

https://www.cityam.com/hundreds-of-investors-hit-home-reit-with-high-court-claims/

Seems to me the shareholders of Octopus Titan might have a good claim against Octopus over unsustainable valuations and fees on those figures. One for the liquidators?

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