UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
MICHAEL ATLAS, on behalf of himself and all
others similarly situated,
CIVIL ACTION NO.
Plaintiff,
CLASS ACTION COMPLAINT
v. FOR VIOLATIONS OF FEDERAL
SECURITIES LAWS
F5 NETWORKS, INC.; JEFFREY HUSSEY;
ROBERT CHAMBERLAIN; CREDIT SUISSE JURY TRIAL DEMANDED
FIRST BOSTON CORP.; DAIN RAUSCHER,
INC.; B.T. ALEX. BROWN, INC.;
FLEETBOSTON ROBERTSON STEPHENS,
INC.; J.P. MORGAN CHASE; and SALOMON
SMITH BARNEY, INC.,
Defendants.
Plaintiff, individually and on behalf of all other persons similarly situated,
undersigned attorneys, for plaintiff's Complaint, allege upon the investigation made by and through
plaintiff's counsel, which included, inter alia, a review of relevant filings made by F5 Networks,
("F5" or 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, this complaint is based upon plaintiff's personal knowledge as to plaintiff
and plaintiff's own acts, and upon 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
related parties, who purchased, converted, exchanged or otherwise acquired F5 common stock, as
defined below, including, but not limited to, during the period from June 4, 1999 through December
6, 2000 (the "Class Period") to recover damages caused by defendants' violations of the federal
securities law.
SNIPPETS:
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
BROWN, INC.; FLEETBOSTON ROBERTSON STEPHENS,
Plaintiff, individually and on behalf of all other persons similarly situated, by plaintiff's
with the Securities and Exchange Commission, as well as, teleconferences, press releases,
related parties, who purchased, converted, exchanged or otherwise acquired F5 common stock, as
2000 (the "Class Period") to recover damages caused by defendants' violations of the federal
alleged malfeasance by major Wall Street securities firms.
York and enforcement officials at the Securities and Exchange Commission are examining
customers in exchange for promises by these customers that they would purchase additional
of the IPOs in the after-market, thereby inflating and maintaining the market price for the
major investment banks including the Underwriter
Defendants, refused to allocate shares of these especially hot IPOs to these customers absent
Commissions for Hot IPOs" by staff reporters Randall Smith and Susan Pulliman.
an early focus of the investigation is defendant investment bank Credit Suisse First Boston
participants in the IPO boom include Morgan Stanley Dean Witter and Goldman Sachs Groups,
kickbacks of trading profits and commitments to purchase additional shares of IPOs in the
would ensure artificial inflation in the IPO stock price, above the offering price, and
profits for investors able to obtain allocations of stock on the offering - - but before the
Securities Act of 1933 15 U.S.C. §§ 77k, 77land 77o and Sections 10
misleading, during the Class Period (including the trading of F5 stock based upon misleading
the underwriter defendants conduct substantial business in this district.
Prospectus and Registration Statement dated June 4,
unlimited access to copies of the reports and press releases alleged herein to be materially
Manipulated Securities omitted and/or misrepresented material facts about the offering of
In direct contravention to Rules 101 and 102 of Regulation M of the Exchange Act,
with direct participation and agreement of F5 and the Individual Defendants.
employed manipulation and/or deceptive devices
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