UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JIMMY CHIN, on behalf of himself and all others
similarly situated,
CIVIL ACTION NO.
Plaintiff,
CLASS ACTION COMPLAINT
v. FOR VIOLATIONS OF FEDERAL
SECURITIES LAWS
PSI TECHNOLOGIES HOLDINGS, INC.;
ARTHUR YOUNG, JR.; THELMA ORIBELLO; JURY TRIAL DEMANDED
HELEN TIU; JOSE CONCEPCION, III; JP
MORGAN CHASE & CO.; FLEETBOSTON
ROBERTSON STEPHENS, INC; THOMAS
WEISEL PARTNERS LLC; BANC OF
AMERICA SECURITIES LLC; THE BEAR
STEARNS COMPANIES INC.;
Defendants.
Plaintiff, individually and on behalf of all other persons similarly situated, by
attorneys, for plaintiff's Complaint, allege upon the investigation made by and through plaintiff's
which included, inter alia, a review of relevant filings made by PSI Technologies Holdings, Inc.
the "Company") with the Securities and Exchange Commission, as well as, tele-conferences, press
releases, news articles, analyst reports, and media reports concerning the Company. Furthermore,
complaint is based upon plaintiff's personal knowledge as to plaintiff and plaintiff's own acts,
information and belief as to all other matters, based upon the aforementioned investigation.
NATURE OF THE ACTION
1. This is a class action on behalf of all persons, other than defendants and
parties, who purchased, converted, exchanged or otherwise acquired PSI common stock, as defined
below, including, but not limited to, during the period from March 16, 2000 through December 6, 2000
(the "Class Period") to recover damages caused by defendants' violations of the federal securities
2. In the wake of the raging bull market of the 1990's lies a series of
alleged malfeasance by major Wall Street securities firms. As reported in national news sources
The New York Times, The Wall Street Journal, and Fortune Magazine, prosecutors in New York and
SNIPPETS:
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
HELEN TIU; JOSE CONCEPCION, III; JP MORGAN CHASE & CO.; FLEETBOSTON ROBERTSON STEPHENS, INC;
Plaintiff, individually and on behalf of all other persons similarly situated, by plaintiff's
which included, inter alia, a review of relevant filings made by PSI Technologies Holdings,
the "Company") with the Securities and Exchange Commission, as well as, tele-conferences,
releases, news articles, analyst reports, and media reports concerning the Company.
This is a class action on behalf of all persons, other than defendants and certain related
parties, who purchased, converted, exchanged or otherwise acquired PSI common stock, as
to recover damages caused by defendants' violations of the federal securities law.
In the wake of the raging bull market of the 1990's lies a series of investigations into
enforcement officials at the Securities and Exchange Commission are examining at least two
investment banks charged issuers of new securities excessive commissions and inflated
Second, investigators are examining, and have evidence, that major investment banks
exchange for promises by these customers that they would purchase additional shares of the
after-market, thereby inflating and maintaining the market price for the IPOs.
Credit Suisse emerged as a leading underwriter of technology
participation in the IPO market and after-market trading.
inflation in the IPO stock price, above the offering price, and create a false sense of
obtain allocations of stock on the offering - - but before the first after-market trade.
Securities Act of 1933 15 U.S.C. '' 77k, 77land 77o and Sections 10and
reports to shareholders of defendants PSI, which documents were materially false and
the Class Period (including the trading of PSI stock based upon misleading information).
underwriter defendants conduct substantial business in this district.
Prospectus dated March 15, 2000, and Registration Statement dated March 15, 2000.
Defendant Thomas Weisel Partners LLC,
In direct contravention to Rules 101 and 102 of Regulation M of the Exchange Act,
participation and agreement of PSI and the Individual Defendants.
disclose the following material facts,
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