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
IBASIS, INC.; OFER GNEEZY; MICHAEL
HUGHES; FLEETBOSTON ROBERTSON JURY TRIAL DEMANDED
STEPHENS, INC.; J.P. MORGAN CHASE; and,
U.S. BANCORP PIPER JAFFRAY 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 iBasis, Inc. ("IBasis" or the
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
plaintiff's personal knowledge as to plaintiff and plaintiff's own acts, and upon information and
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 IBasis common stock, as defined
below, including, but not limited to, during the period from November 10, 1999 through December 6,
2000 (the "Class Period") to recover damages caused by defendants' violations of the federal
law.
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
SNIPPETS:
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
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 iBasis, Inc. with
the Securities and Exchange Commission, as well as, tele-conferences, press releases, news
analyst reports, and media reports concerning the Company.
This is a class action on behalf of all persons, other than defendants and certain related
2000 (the "Class Period") to recover damages caused by defendants' violations of the federal
In the wake of the raging bull market of the 1990's lies a series of investigations into
alleged malfeasance by major Wall Street securities firms.
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.
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
including the preparation and dissemination in this judicial district of the Prospectus
misleading, during the Class Period (including the trading of IBasis stock based upon
the underwriter defendants conduct substantial business in this district.
control to cause the Company to engage in the violations and improper practices complained of
and/or managing underwriter of the IBasis initial public offering of 6,800,000 shares of
copies of the reports and press releases alleged herein to be materially false and/or
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,
participation and agreement of IBasis and the Individual Defendants.
violation of Regulation M, which governs market manipulation.
plaintiff and the other members of the Class acquired IBasis common stock during the Class
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