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1
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CONSOLIDATED AND AMENDED COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS SALES ACQUISITIONS STOCK SEEDS BUSINESS SECURITIES CASH REVENUE OFFICER FINANCIALS MATERIALLY FALSE DEFENDANT THOMAS GROWTH MISLEADING ANNUALIZED NET SALES PLAINTIFFS MANAGEMENT ACQUIRED COMPANIES ACCOUNTING INTERCOMPANY SALES CONSOLIDATION DEFENDANT INGALLS CLASS ACTION DISTRIBUTION NETWORK BUSINESS WIRE REASONS SET FINANCIAL POSITION INDIVIDUAL DEFENDANTS |
file:///CI/My Documents/Clare/woIfh/abtx.htm
- - Plaintiffs' Co-Lead Counsel
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
)
In re AgriBioTech, Inc. ) Base File No. CV-S-99-144-PMP (LRL)
SECURITIES LITIGATION )
)
) CLASS ACTION
This Document Relates To: )
ALL ACTIONS ) JURY TRIAL DEMANDED
CONSOLIDATED AMENDED COMPLAINT
INTRODUCTION AND OVERVIEW
1. This is a securities class action brought on behalf of purchasers of the
AgriBioTech, Inc. ("AgriBioTech" or the "Company") between September 24,
16, 1999, inclusive (the Tlass Period"), alleging a scheme and course of
fraud and deceit on purchasers of AgriBioTech securities. The defendants are
top officers (collectively the "defendants"). AgriBioTech operates
seed development and breeding programs, seed processing plants and a sales
AgriBioTech had limited sales until January 1, 1995, when it began its
implemented its business strategy of growth through acquisitions -- making 33
combination of stock and cash as currency. By June 1998, only three and
inception, AgriBioTech had advanced through acquisitions from-virtually
share in the $1.1 billion forage and turf seed sector.
2. In 1995, the turfseed development industry was highly fragmented,
privately held businesses. Defendants embarked upon a plan to consolidate
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