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IN THE COURT OF CHANCERY IN THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JAMES V. BIGLAN,
Plaintiff,
CIVIL ACTION NO. 1
V.
CHARLES R. STUCKEY, JR., D. JAMES
BIDZOS, RICHARD L. EARNEST,
DR. TAHER ELGAMAL, JAMES K. SIMS,
ROBERT P. BADAVAS, JOSEPH B.
LASSITER, III, ARTHUR W. COVIELLO,
and VERISIGN, INC.,
Defendants,
and
RSA SECURITY INC., f/k/a SECURITY
DYNAMICS TECHNOLOGIES, INC.,
Nominal Defendant.
SHAREHOLDER
Plaintiff alleges, upon information and belief, except as to paragraph 3 which is alleged
upon personal knowledge, the following.
--ION
1. Plaintiff brings this action derivatively as a shareholder of RSA Security, Inc.,
formerly known as Security Dynamics Technologies, Inc. ("RSA" or the "Company") in the name
of and on behalf of the Company which is named as a Nominal Defendant.
SNIPPETS:
IN THE COURT OF CHANCERY IN THE STATE OF DELAWARE
JAMES V. BIGLAN,
RSA SECURITY INC., f/k/a SECURITY
Plaintiff alleges, upon information and belief, except as to paragraph 3 which is alleged
upon personal knowledge, the following.
formerly known as Security Dynamics Technologies, Inc. in the name
of and on behalf of the Company which is named as a Nominal Defendant.
Bidzos has also served as Vice Chairman and Chairman of defendant VeriSign,
Defendant Charles R. Stuckey,
Defendants Richard L. Earnest, Dr. Taher Elgamal, James K. Sims, Robert P
Each of the Individual Defendants owed RSA and its public shareholders the
business and affairs of RSA carefully and prudently; neither violate nor knowingly permit any
In violation of their fiduciary duties,
to protect the Company's valuable intellectual property; failing to enforce the terms of the
Security Dynamics Technologies, Inc. was founded in 1986,
Security Dynamics acquired RSA Data in July
The Company's encryption security software components
incorporate RSA encryption technology into their products, and also licenses its products
RSA offers various "toolkits," built around RSA's public key cryptographic
VeriSign entered into an OEM Master License Agreement,
million shares of VeriSign common stock.
of digital certificates, is in a position, given its willingness to violate the terms of the
e f endants Have Subjected Themselves to Federal Securities Class Action Lawsuit
at the time) sold stock in a public offering pursuant to a Registration Statement and
The Company currently experiences competition from a number of
represents a gross waste of RSA's valuable corporate assets.
This action is brought pursuant to remedy violations of applicable state laws.
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