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1
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COMPLAINT
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EXTRACTED KEY WORDS
INDIVIDUAL DEFENDANTS NETWORKS DSL PLAINTIFF ACT SECURITIES MARKET CLECS BUSINESS FIDUCIARY DUTIES PRICE GILBERT SHAREHOLDERS DIRECTORS MISLEADING INVESTORS COSTS ILECS CUSTOMERS FEDERAL SECURITIES CLASS ACTION SDSL TELECOMMUNICATIONS ACT COMPETITIVE CARRIERS INCUMBENT SECURITIES FRAUD SECURITIES FRAUD LITIGATION PAY SUBSTANTIAL DEFENSE MULTI-MILLION DOLLAR JUDGMENT |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
i
CAROL GLASSMAN,
Plaintiff,
vs.
RICHARD S. GILBERT, JOSE:PH D. >
MANKEE, ROBERT L. BAILEY, TENCH ) COMPLAINT
COX, ROGrER EVANS, RICHARD H.
KIMBALL, RAYMOND V. THOMAS, ;
AND ANDREW W. VERHALEN,
i
Defendants, >
and
i
COPPER MOUNTAIN NETWORKS, INC., )
>
Nominal Defendant. >
Plaintiff alleges upon personal knowledge as to herself and her own acts, and on
information and belief as to all other matters, as follows:
NATURE OF THE ACTION
1. In violation of their fiduciary duties owed to the Company and its shareholders, the
individual defendants, who constitute the Board of Directors of Copper Mountain Networks, Inc.
("Cooper Mountain" or the "Company"), caused the Company to issue false and misleading
statements to Copper Mountain's shareholders and investors which inflated the price of Copper
Mountain's securities and caused it to be named as a defendant in federal securities fraud
litigation. `The exposure to this, securities fraud litigation has caused and will cause the Company
to incur and pay substantial defense related costs and a possible multi-million dollar judgment
and/or settlement.
2. Plaintiff brings this action derivatively in the right and for the benefit of Copper
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