UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
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WAYNE E. MEYER, Individually and On Behalf of : Case No.
All Others Similarly Situated, :
:
Plaintiff, : CLASS ACTION
: COMPLAINT FOR
- against - : VIOLATION OF
: FEDERAL
LUCENT TECHNOLOGIES, INC., RICHARD A. : LAW
MCGINN, and DONALD K. PETERSON, :
Defendants. : Jury Trial Demanded
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Plaintiff individually and on behalf of all others similarly situated, by his
undersigned attorneys, for their Class Action Complaint, allege upon personal knowledge as to
himself and his own acts, and upon information and belief as to all other matters, based upon,
inter alia, the investigation made by and through their attorneys, which investigation included,
among other things, a review of the public documents and new releases of Lucent Technologies,
Inc. ("Lucent" or the "Company")
NATURE OF THE ACTION
1. This is a class action on behalf of all purchasers of the common stock of Lucent
Technologies, Inc. ("Lucent" or the "Company") who purchased or otherwise acquired such
stock between July 20, 2000 and December 20, 2000, inclusive ("the Class Period"), to recover
for injuries suffered from defendants' violations of the federal securities laws. During the Class
Period, defendants issued to the investigating public materially false and misleading financial
information concerning the Company's publicly reported revenues and earnings.
2. During the Class Period, Lucent improperly recognized approximately $679
million in revenue and announced that it would restate its fiscal fourth quarter financial
statements for a second time. During the Class Period, the Company improperly recognized
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Plaintiff individually and on behalf of all others similarly situated,
undersigned attorneys, for their Class Action Complaint, allege upon personal knowledge as to
among other things, a review of the public documents and new releases of Lucent Technologies,
for injuries suffered from defendants' violations of the federal securities laws.
defendants issued to the investigating public materially false and misleading financial
information concerning the Company's publicly reported revenues and earnings.
million in revenue and announced that it would restate its fiscal fourth quarter financial
of 1934 ("Exchange Act"), 15 U.S.C. §§ 78jand 78t;
section 27 of the Exchange Act, 15 U.S.C. § 78aa; and on sections 1331 and 1337of the
States mails and the facilities of the national securities exchanges.
President and Chief Executive Officer of Lucent.
Company's stock and would cause the price of the Company's stock to become artificially
fraud and deceit upon plaintiff and the other members of the Class.
Plaintiff brings this action as a class action pursuant to Federal Rule of Civil
otherwise acquired shares of Lucent common stock between July 20, 2000 and December 20,
of revenue in violation of Generally Accepted Accounting Principals and SEC rules.
Two other cases involving sales teams' customer credit
December 21, 2000, far from the class period high of $54 3/16 per share.
GAAP are those principles recognized by the accounting profession as the
SEC Regulation S-X ) states that financial statements
The principle that interim financial reporting should be based upon the same accounting
The principle that financial reporting should provide information that is useful to present
The principle that financial reporting should provide information about how management of an
In ignorance of the artificially high market prices of Lucent's publicly traded
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