UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JIMMY K.V. CHIN, on behalf of himself and all
others similarly situated, CIVIL ACTION NO.
Plaintiff, CLASS ACTION COMPLAINT
v. FOR VIOLATIONS OF FEDERAL
SECURITIES LAWS
INTEGRATED INFORMATION SYSTEMS,
INC.; JAMES G. GARVEY, JR.; DAVID JURY TRIAL DEMANDED
WIRTHLIN; FLEETBOSTON ROBERTSON
STEPHENS, INC.; U.S. BANCORP PIPER
JAFFRAY, INC.; ROBERT W. BAIRD & CO.,
INCORPORATED; LEGG MASON, INC.; J.P.
MORGAN CHASE & CO.; and DEUTSCHE
BANK SECURITIES, 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 Integrated Information Systems,
("Integrated" 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
Furthermore, this complaint is based upon plaintiff's personal knowledge as to plaintiff and
acts, and upon information and belief as to all other matters, based upon the aforementioned
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 Integrated Information common
stock, as defined below, including, but not limited to, during the period from March 17, 2000
December 6, 2000 (the "Class Period") to recover damages caused by defendants' violations of the
securities law.
2. In the wake of the raging bull market of the 1990's lies a series of
malfeasance by major Wall Street securities firms. As reported in national news sources such as
York Times, The Wall Street Journal, and Fortune Magazine, prosecutors in New York and
SNIPPETS:
WIRTHLIN; FLEETBOSTON ROBERTSON STEPHENS, INC.; U.S. BANCORP PIPER JAFFRAY, INC.; ROBERT W.
BANK SECURITIES, INC.,
which included, inter alia, a review of relevant filings made by Integrated Information
with the Securities and Exchange Commission, as well as, teleconferences, press releases,
this complaint is based upon plaintiff's personal knowledge as to plaintiff and plaintiff's
2000 (the "Class Period") to recover damages caused by defendants' violations of the federal
malfeasance by major Wall Street securities firms.
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
allocated shares of especially hot initial public offerings to favored,
for promises by these customers that they would purchase additional shares of the IPOs in the
the IPO boom include Morgan Stanley Dean Witter and Goldman Sachs Groups,
and maintain the price of the IPOs in the aftermarket once the initial distribution period
stock price, above the offering price, and create a false sense of demand that would attract
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
misleading, during the Class Period (including the trading of Integrated Information stock
the underwriter defendants conduct substantial business in this district.
According to the Prospectus, Integrated
the price of Integrated Information common stock to be artificially inflated.
of the reports and press releases alleged herein to be materially false and/or misleading
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 Integrated Information and the Individual
violation of Regulation M, which governs market manipulation.
members of the Class would not have purchased or otherwise acquired Integrated Information
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