IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
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MARTIN COHEN, SORYL COHEN, DANIEL J. KUCERA, and MARK LENET, On Behalf
of Themselves and All Others Similarly Situated,
Plaintiff,
vs.
CITRIX SYSTEMS INC., MARK B. TEMPLETON, JOHN P. CUNNINGHAM and EDWARD
E. IACOBUCCI Defendants.
Defendants.
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No. 006814
PLAINTIFFS' CLASS ACTION COMPLAINT
Plaintiffs, by and through their attorneys, allege the following upon
the investigation of counsel, except as to those allegations
concerning plaintiffs, which are alleged upon personal knowledge,
including, among other things, the investigation of their attorneys,
including without limitation: (a) review and analysis of public
filings made by Citrix Systems, Inc. ("Citrix," or the "Company"),
with the Securities and Exchange Commission (the "SEC"); (b) review
and analysis of securities analysts' reports concerning Citrix;
(c) review and analysis of press releases and other publications
disseminated by defendants; and (d) other publicly available
SNIPPETS:
CITRIX SYSTEMS INC., MARK B. TEMPLETON, JOHN P. CUNNINGHAM and EDWARD E. IACOBUCCI Defendants.
PLAINTIFFS' CLASS ACTION COMPLAINT
Plaintiffs, by and through their attorneys, allege the following upon the investigation of
alysis of press releases and other publications disseminated by defendants; and other publicly
This action is brought as a class action on behalf of all persons who purchased the common
Plaintiffs' claims arise under Section 10of the Securities Exchange Act of 1934 and SEC Rule
a substantial number of the false and misleading statements complained of were prepared and
In connection with the violations of law alleged herein, the defendants used the means and
Plaintiffs purchased shares of Citrix at artificially inflated prices during the Class Period,
Defendant Citrix is an application server software and services provider.
Defendant Mark B. Templeton has, at all material times, been the Company's Chief Executive
Defendant John P. Cunningham has been the Company's Chief Financial Officer since November,
Defendant Cunningham is responsible for signing many of the Company's false and misleading
Defendant Edward E. Iacobucci is the co-founder of the Company and has served as Chairman of
On June 12, 2000, Citrix took investors and analysts by surprise, announcing that the
For the quarter, Citrix announced that it expects to report total revenue in the range of
the price of Citrix common stock fell over 40% to $22 per share - - a far cry from the
While investors were caught by surprise, defendants had, for some time, been concealing the
Those statements appeared in public filings with the SEC and in Citrix press releases.
the misleading representations were disseminated by defendants to the public through press
SCIENTER ALLEGATIONS
As alleged herein, defendants acted with scienter in that defendants knew that the public
ecurities laws.
Defendant Iacobucci sold 200,000 of his own shares on February 6, 2000, generating proceeds
The market price for Citrix common stock reflected the information publicly available about
Excluded from the Class are the defendants, members of the defendants' immediate families,
Net income, excluding certain write-offs, was $34.2 million, or $0.35 per share, as compared
For the first nine months of 1999, net revenues were $285.2 million, a 65% increase for the
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