UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
)
MARKET STREET SECURITIES, ) Case No.
Individually And On Behalf Of All Others ) 00C3267
Similarly Situated, ) CLASS ACTION COMPLAINT
Plaintiff, ) ) FOR VIOLATIONS OF
vs. ) FEDERAL SECURITIES LAWS
)
RACING CHAMPIONS CORP., ) )
ROBERT DODS, CURTIS )
STOELTING, and VICTOR )
SHAFFER, ) JURY TRIAL DEMANDED
Defendants.
1. Plaintiff has alleged the following based upon the investigation of plaintiff's
counsel, which included a review of United States Securities and Exchange
Commission ("SEC") filings by Racing Champions Corp. ("Racing Champions" or
the "Company"), as well as regulatory filings and reports, securities analysts
reports and advisories about the Company, press releases and other public
statements issued by the Company, and media reports about the Company, and
plaintiff believes that substantial additional evidentiary support will exist for the
allegations set forth herein after a reasonable opportunity for discovery.
NATURE OF THE ACTION
2. This is a federal class action on behalf of all purchasers of the common stock of
Racing Champions between February 1, 1999, and June 23, 1999, inclusive (the
"Class Period"), to recover damages for violation of the Securities Exchange Act
of 1934 (the "Exchange Act").
JURISDICTION AND VENUE
3. The claims asserted herein arise under and pursuant to Sections 10(b) and 20(a)
of the Exchange Act [15 U.S.C. §§ 78j(b) and 78t(a)] and Rule 10b-5 promulgated
thereunder by the Securities and Exchange Commission ("SEC") [17 C.F.R.
§ 240.10b-5].
4. This Court has jurisdiction over the subject matter of this action pursuant to 28
U.S.C. §§ 1331 and 1337 and Section 27 of the Exchange Act [15 U.S.C. § 78aa].
5. Venue is proper in this District pursuant to Section 27 of the Exchange Act, and
28 U.S.C. § 1391(b). Many of the acts charged herein, including the preparation
SNIPPETS:
Plaintiff has alleged the following based upon the investigation of plaintiff's
which included a review of United States Securities and Exchange
Commission filings by Racing Champions Corp. ("Racing Champions" or
the "Company"), as well as regulatory filings and reports, securities analysts
to recover damages for violation of the Securities Exchange Act
defendants maintain their chief executive offices and principal place of business within this
Plaintiff, Market Street Securities, as set forth in the accompanying certification,
The individual defendants identified below, served at all times material to the claims set
Because of the Individual Defendants' positions with the Company, they had access to the
rovided to them in connection therewith.
It is appropriate to treat the Individual Defendants as a group for pleading purposes and to
Each of the above officers of Racing Champions by virtue of their high-level positions with
As officers and controlling persons of a publicly-held company whose common stock was, and
ements, business, products, markets, management, earnings and present and future business
The Individual Defendants participated in the drafting, preparation, and/or approval of the
Each of the defendants is liable as a participant in a fraudulent scheme and course of
deceived the investing public regarding the Company's business, product demand, growth,
PLAINTIFF'S CLASS ACTION ALLEGATIONS
Racing Champions manufactures and distributes officially licensed NASCAR miniature racing
Second, and more importantly, the introduction of Star Wars-related toys was negatively
Champions' participation in the rapidly expanding market for collectibles.
Relying on Dods' glowing statement about the Ertl acquisition First Union Capital Markets Co.
The implementation of this business strategy is nothing less than an admission by Racing
During the Class Period, defendants materially misled the investing public, thereby inflating
the material misrepresentations and omissions particularized in this Complaint directly or
Company were materially false and misleading; knew that such statements or documents would be
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