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1
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS CLASS PERIOD STOCK PLAINTIFF SECURITY EXCHANGE ACT COMMON STOCK CLASS ACTION SECURITIES DAMAGES CLASS MEMBERS PRICE SUFFERED DAMAGES NOONAN INTERNET SECURITY SYSTEMS INDIVIDUAL DEFENDANTS ARTIFICIALLY HIGH UNITED STATES ALLEGATIONS PROTECTION FINANCIALS MISLEADING EXPECTATIONS INTRUSION DETECTION STATES DISTRICT COURT DISSEMINATION STRATEGIC ALLIANCES MANAGEMENT MISREPRESENTATIONS |
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
______________________________________
:
MASOOD AMINTINAT, on behalf of :
himself and all others similarly situated, :
:
Plaintiff, : CIVIL ACTION NO.
:
v. :
:
INTERNET SECURITY SYSTEMS, INC., :
RICHARD MACCHIA, CHRISTOPHER :
KLAUS, and THOMAS E. NOONAN, :
:
Defendants. :
______________________________________:
CLASS ACTION COMPLAINT
Plaintiff, by and through counsel, alleges the following on personal
knowledge as to these allegations concerning Plaintiff personally, and as to all other
matters, on investigation of counsel, which included review and analysis of press
releases made by defendant Internet Security Systems (ISS) and other publicly
available information, including, on-line research and a review of the web site of
ISS.
NATURE OF THE ACTION
1. This is a class action under the Securities Exchange Act of 1934
(the "Exchange Act") on behalf of all persons who purchased or otherwise
acquired the common stock of ISS between April 5, 2001 and July 2, 2001 (the
"class period") and who suffered damages as a result of defendants' fraud (the
"class").
2. During the class period, on April 18, 2001, ISS reported its 23rd
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