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1
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CONSOLIDATED AMENDED COMPLAINT
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EXTRACTED KEY WORDS
CCSI DEFENDANTS CHROMATICS MISLEADING MATERIALLY FALSE PLAINTIFFS UNITED STATES EXCHANGE ACT SECURITIES MARKET CLASS ACTION YORK BILIRUBIN COLORMATE DEVICE COMMON STOCK TECHNOLOGY INDIVIDUAL DEFENDANTS DISTRIBUTION BILIRUBIN INFANT MONITORING MATERIAL FACTS BUSINESS PROSPECTS ALLEGATIONS BLOOD TESTS INSTRUMENT COMMERCIAL DISTRIBUTION W-OLF POPPER LLP INFANT JAUNDICE CORPORATE OFFICERS |
W-OLF POPPER LLP
Stephen D. Oestreich (SDO 8933)
Carl L. Stine (CLS 3000)
845 Third Avenue
New York, New York 10022
(2 12) 759-4600
Plaintiffs' Lead Counsel
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
"`-"""-""-`--`----------*--------------*-----------*-----~
TN RE CHROMATICS COLOR SCIENCES `: Consolidated
INTERNATIONAL INC. 98 Civ. 31 I1
SECURITIES LITIGATION
""-"""-`-"-`-`-"-`--------------------------------------*---x Juw Trial
CONSOLIDATED AMENDED CLASS ACTION COMPLATiST
Plaintiffs, by their attorneys, on behalf of themselves and the
represent, for their Consclidated Amended Class Action Complaint (the "Complaint"), make
following allegations against defendants upon information and belief(except as to
specifically pertaining to plaintiffs and their counsel, which are based on personal
based upon the thorough investigation conducted by and under the supervision of
counsel.
NATURE OF THE ACTION
1. This is a class action on behalf of all purchasers of
Chromatics Color Sciences International, Inc. ("CCSI" or the "Company") between July 30,
1997 and June 9, 1998, inclusive (the "Class Period"), seeking to pursue remedies under
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2
.
COMPLAINT
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EXTRACTED KEY WORDS
COLORMATE BILIRUBIN REPORT TECHNOLOGY MEASUREMENT AVON MARKET PATENTS COST INVESTORS INSTRUMENT ASENSIO TIC-BILIMETER JAUNDICE SKIN PRINCIPALS WARRANTS SHARES OFFERING REVENUE BLOOD INDUSTRY COMMON EMPLOYEE EXPENSES APPLICATIONS BUSINESS HOSPITALS NEWBORNS |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
------------------ --
L. F. M3rlK,
No.
Plaintiff,
I
COMPLAIN
- against - /
I
/
CHROMATICS COLOR SCIENCES / 1
INTERNATIONAL INC.,DARBY_ S., I
MACFARLANE, ARTHUR GUIR?, DAVID K. / '
MACFARLANE and LESLIE FOGLESONG, j ,
Defdndants.
Plaintiff, individually and on behalf
similarly situated, by his attorneys,
upon
information and belief (except for those
to G:lair:ciff I
which are based on personal
NATURE OF THE ACTION
1. Plaintiff brings this
on
behzif of. a class (the "Class") consisting
( 1
other persons or entities who purchased
I
securities of. defendant CHROMATICS COLOR SCIENCES INTEI
INC., (l'Chromaticsll or the 10Companyll) during
1997 through ;rune 9, 1998, inclusive (the
recover damages caused to the Class by defendants'
of
the federal securities laws.
i
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