IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
CASE NO. __________________
IKCYBERINVESTMENTS, on behalf of
itself and all others similarly situated,
Plaintiff,
v.
PARTSBASE.COM, INC., ROBERT A.
HAMMOND, JR., STEVEN R. SPENCER, CLASS ACTION COMPLAINT
MICHAEL SIEGEL, THOMAS VAN HARE,
LOUIS W. STORMS IV, ROTH CAPITAL JURY TRIAL DEMANDED
PARTNERS, INC. and PMG CAPITAL CORP.
(formerly PENN MERCHANT GROUP,
LTD.),
Defendants.
Plaintiff, individually and on behalf of all others similarly situated, by its undersigned
attorneys, for its Class Action Complaint, alleges upon personal knowledge as to itself and its
own acts, and upon information and belief as to all other matters, based upon an investigation
made by and through counsel, which included a review of the public documents and new releases
of PartsBase.com, Inc. ("PartsBase" or the "Company")
NATURE OF THE ACTION
1. This is a securities class action on behalf of all persons and entities that
PartsBase stock in or traceable to the Company's initial public offering ("IPO") up to and
including April 25, 2000, pursuant to a registration statement ("Registration Statement") and
prospectus ("Prospectus") declared effective on March 22, 2000 by the Securities and Exchange
1
Commission ("SEC") (the "Class"). The Offering was for 3,500,000 shares of common stock at
SNIPPETS:
Plaintiff, individually and on behalf of all others similarly situated, by its undersigned
of PartsBase.com,
including April 25, 2000, pursuant to a registration statement and
The Offering was for 3,500,000 shares of common stock at
its members to buy and sell new, used and overhauled aviation parts and products.
Registration Statement and Prospectus.
it had more than 13,000 members, in reality it had only about 3,000 paying members.
investors suffered millions of dollars in damages.
far below the offering price of $13 per share.
misleading information, including the Registration Statement and Prospectus pursuant to which
defendants, directing and indirectly, used the means and instrumentalities of interstate
At all relevant times, Defendant Robert A. Hammond, Jr.
the Offering and was involved in selling shares of PartsBase to the public.
maintains its principal place of business in Newport Beach,
Defendant PMG Capital Corp. was a lead underwriter for the Offering
representatives, heirs, successors and assigns of any excluded person.
and all members of the Class sustained damages as a result of the violations of the
PartsBase common stock at $13 per share.
In order to continue our membership growth and increase our worldwide market penetration, we
and failed to disclose adequately material facts concerning PartsBase's
The Prospectus contained untrue statements of material facts and omitted to state
defendants and seek rescission of their purchases to the extent that they continue to own such
For Violations of Section 15 of the Securities Act
The Individual Defendants acted as controlling persons of PartsBase within the
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