KAPLAN, KILSHEIMER & FOX LLP
WILLIAM J. PINLIS
Attorney at Law
237 South Street
Morristown, NJ 07960
(WJP2130)
Tel. 973/656-0222
Fax 973/401-1114
Attorney for Plaintiff
[Additional counsel appear on signature page.]
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
)
YUNUS DADABHOY, On Behalf of Himself ) No. ______________
and All Others Similarly Situated, )
) CLASS ACTION
Plaintiffs, )
) COMPLAINT FOR VIOLATION OF THE
vs. ) FEDERAL SECURITIES LAWS
)
NICE SYSTEMS, LTD, BENJAMIN )
LEVIN and YUVAL YANAI, )
)
Defendants. )
) DEMAND FOR JURY TRIAL
SUMMARY OF THE ACTION
1. This is a securities fraud class action on behalf of persons who purchased NICE
Ltd. ("NICE Systems" or the "Company") American Depository Shares ("ADS's") between February 16,
2000 and February 7, 2001 (the "Class Period"), against NICE Systems and its top two officers for
violations of the federal securities laws arising out of defendants' dissemination of false and
statements concerning the Company's financial results for fiscal 1999 and portions of fiscal 2000.
2. NICE Systems, headquartered in Ra'anana, Israel, describes itself as a worldwide
multimedia digital recording solutions, applications and related professional services for business
management. NICE products and solutions are used in contact centers, trading floors, air traffic
(ATC) sites, CCTV (closed circuit television) security installations and Government markets. NICE's
SNIPPETS:
Fax 973/401-1114 Attorney for Plaintiff
This is a securities fraud class action on behalf of persons who purchased NICE Systems,
Ltd. American Depository Shares between February 16,
violations of the federal securities laws arising out of defendants' dissemination of false
applications and related professional services for business interaction
NICE products and solutions are used in contact centers, trading floors, air traffic control
CCTV security installations and Government markets.
synergistic technology platform enables customers to capture, evaluate and analyze business
The Company's U.S. headquarters are located in Secaucus,
misleading financial statements for fiscal year 1999 and the first three quarters of fiscal
improperly recognized material amounts of revenue, in violation of Generally Accepted
Principles, on among other things, consignment "sales" where revenue should not have been
a worldwide leader of multimedia digital recording
solutions, applications and related professional services for business interaction management,
to the improper recognition of revenue, the price of NICE Systems' ADS's fell almost 30% in
NICE serves the business needs of multiple markets, primarily financial institutions,
Chief Financial Officer from April 1998 until he left the Company in December 2000.
Net income for the year, excluding one-time charges,
This press release was materially false and misleading.
On February 23, 2000, NICE Systems issued a press release announcing its acquisition of
On November 1, 2000, NICE Systems also issued a press release announcing its intention to
By reason of the foregoing, the defendants have violated Section 10of the Exchange Act
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