CKS GROUP CLASS ACTION LITIGATION - Legal Case Documents


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CKS GROUP CLASS ACTION LITIGATION

Keywords & Phrases

CaseNo: CGCAL171888, CourtName: CLASS ACTION CASES, State: PA Pennsylvania, UniqueCaseRef: LCD>CGCAL171888, Cks, Cedar, Dominion, Securities, Lead Plaintiffs, Exchange Act, Wilson Plaintiffs, Class Action, Motion, Misleading, Revenue, Co-lead Counsel, Kvamme, Mallison, Financials, Dominion Bridge, Marengere, San Francisco, Class Period, Securities Exchange Act, United States, Cedar Group, Firm, Stock, Report, Lead Plaintiffs Pursuant, Olsen Law Firm, California, Analysts, Lerach Llp, Gross Violations, Matossian, Law Firm, Baab, Business Condition, Marketing, Price, Subsidiaries , ContentID: 120249571

Case Documents

MOTION AND MEMO IN SUPPORT OF MOTION TO BE APPOINTED
[ see first page and extracted highlights below ] ItemID: 122126

12 pages
TXT

LITIGANTS
[ see first page and extracted highlights below ] ItemID: 122125

2 pages
TXT

DECLARATION OF STANLEY S
[ see first page and extracted highlights below ] ItemID: 122123

5 pages
TXT

AMENDED COMPLAINT
[ see first page and extracted highlights below ] ItemID: 122121

32 pages
TXT

1999-02-10

DOCKET
[ see first page and extracted highlights below ] ItemID: 122124

2 pages
TXT

1996-10-07

COMPLAINT
[ see first page and extracted highlights below ] ItemID: 122122

21 pages
HTML

Total Documents: 6 documents , 74 pages

Price: $ 44.95

IVESLCD01 KGI0001

1 . MOTION AND MEMO IN SUPPORT OF MOTION TO BE APPOINTED

EXTRACTED KEY WORDS

LEAD PLAINTIFFS
WILSON PLAINTIFFS
EXCHANGE ACT
MOTION
CO-LEAD COUNSEL
MALLISON
COURT
SECURITIES EXCHANGE ACT
CKS
LEAD PLAINTIFFS PURSUANT
DEFENDANTS
LAW FIRM
APPOINTED LEAD PLAINTIFFS
SAN FRANCISCO
MILBERG WEISS
CLASS MEMBERS
OLSEN LAW FIRM
LERACH LLP
MALLISON DECL
MEMORANDUM
CALIFORNIA
AUTHORITIES
UNITED STATES
MILBERG WEISS BERSHAD
CKS STOCK
NORTHERN DISTRICT
KATHREIN
COLLECTIVELY APPOINTED LEAD
ADEQUATE PLAINTIFF



   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   LISA C. ATKINSON (163320)

   STANLEY S. MALLISON (184181)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   415/288-4534 (fax)

   BERGER & MONTAGUE, P.C.

   TODD S. COLLINS

   JACOB A. GOLDBERG

   1622 Locust Street

   Philadelphia, PA 19103

   Telephone: 215/875-3000

   THE OLSEN LAW FIRM

   KURT B. OLSEN

   2121 "K" Street, NW

SNIPPETS:

- and -REED R. KATHREIN

San Francisco, CA 94108

THE OLSEN LAW FIRM

Co-Lead Counsel for Plaintiffs

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

CKS GROUP, INC., et al.,

THE WILSON PLAINTIFFS GROUP'S NOTICE OF MOTION,

TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO SECTION

21DOF THE SECURITIES EXCHANGE ACT OF 1934 AND FOR

APPROVAL OF LEAD PLAINTIFFS' CHOICE OF CO-LEAD COUNSEL

MOVANTS ARE THE MOST ADEQUATE PLAINTIFFS UNDER THE EXCHANGE ACT

The Wilson Plaintiffs Group Has The Largest Financial Interest In The Related Actions

THIS COURT SHOULD APPROVE THE WILSON PLAINTIFFS GROUP'S CHOICE OF CO-LEAD COUNSEL

In addition, Movants seek the Court's approval of their selection of Milberg Weiss Bershad

This motion is based upon this notice, the accompanying memorandum of points and authorities,

Under this provision of the Exchange Act, the Court "shall" appoint the "most adequate

Here, the Wilson Plaintiffs Group constitutes class members who collectively purchased 158

The notice advised purchasers of CKS stock of the existence of this lawsuit and the nature of

See the firm resumes of Milberg Weiss; Berger & Montague, P.C.; and The Olsen Law Firm

PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2

Mar. 28, 1997) (eleven individual plaintiffs with the largest financial interest collectively

2 . LITIGANTS

EXTRACTED KEY WORDS

DISTRICT
CKS GROUP
WILSON
BAAB
CARLTON
SUITER
THOMAS
KVAMME
MARK
ALAN SCHULMAN
ROBERT
CALIFORNIA
NORTHERN DISTRICT
DISTRICT COURT

3:98cv4229 Wilson v. CKS Group, Inc., et al

                       U.S. District Court
  U.S. District for the Northern District of California (S.F.)


ROBERT E. WILSON, On behalf of    Alan Schulman
himself and all others            (COR LD NTC)
similarly situated                William S. Lerach
     Plaintiff                    (COR LD NTC)
                                  Milberg Weiss Bershad Hynes &
                                  Lerach LLP
                                  600 W Broadway Ste 1800
                                  One America Plaza
                                  San Diego, CA 92101
                                  (619) 231-1058

                                  Todd S. Collins
                                  (COR LD NTC)
                                  Jacob A. Goldberg
                                  (COR LD NTC)
                                  Berger & Montague, P.C.
                                  1622 Locust St
                                  Philadelphia, PA 19103
                                  (215) 875-3000

                                  Reed R. Kathrein
                                  (COR LD NTC)
                                  Lisa C. Atkinson
                                  (COR LD NTC)
                                  Stanley S. Mallison
                                  415-288-4545
                                  10th Floor
                                  (COR LD NTC)
                                  Milberg Weiss Bershad Hynes &
                                  Lerach LLP
                                  222 Kearney St 10th Flr
                                  San Francisco, CA 94108
                                  (415) 288-4545

                                  Kurt Olsen
                                  (COR LD NTC)
                                  Olsen Law Firm
                                  2300 N. Street, N.W.
                                  Suite 600
                                  Washington, DC 20037
                                  (202) 663-9331

SNIPPETS:

3:98cv4229 Wilson v. CKS Group, Inc., et al

U.S. District Court

U.S. District for the Northern District of California

ROBERT E. WILSON, On behalf of Alan Schulman

CKS GROUP, INC. defendant

MARK D. KVAMME

THOMAS K. SUITER

CARLTON H. BAAB

3 . DECLARATION OF STANLEY S

EXTRACTED KEY WORDS

EXHIBIT
APPOINTMENT
COUNSEL
MOTION
DECLARATION
CALIFORNIA
SAN FRANCISCO
LEAD PLAINTIFFS PURSUANT
FIRM
LITIG
APPROVING
SECURITIES EXCHANGE ACT
WILSON PLAINTIFFS
UNITED STATES
CO-LEAD COUNSEL
LAW FIRM
MALLISON
STANLEY
ORDER GRANTING
LERACH LLP
MASTER FILE
SUPPORT
NORTHERN DISTRICT
OLSEN LAW FIRM
WEISS BERSHAD HYNES
MILBERG WEISS BERSHAD
SBA
BUSINESS
THERETO



   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   LISA C. ATKINSON (163320)

   STANLEY S. MALLISON (184181)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   415/288-4534 (fax)

   BERGER & MONTAGUE, P.C.

   TODD S. COLLINS

   JACOB A. GOLDBERG

   1622 Locust Street

   Philadelphia, PA 19103

   Telephone: 215/875-3000

   THE OLSEN LAW FIRM

   KURT B. OLSEN

   2121 "K" Street, NW

SNIPPETS:

STANLEY S. MALLISON

UNITED STATES DISTRICT COURT

OF LEAD PLAINTIFFS' CHOICE OF CO-LEAD COUNSEL

I am an attorney duly licensed to practice law in the State of California and am admitted to

I am associated with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, one of counsel

I make this Declaration in Support of the Wilson Plaintiffs Group's Motion to Be Appointed of

I have personal knowledge of the facts set forth below and if called as a witness could and

Exhibit B: Movant's Purchases, Sales and Losses Chart.

Notice to the class of the filing of the Wilson action, published on the Business Wire on

Sec. Litig., No. C 96-2644 SBA, Order re Appointment of Lead Plaintiff and Lead Counsel (N.D.

Sec. Litig., NO. C-97-20059 RMW, Order Granting Plaintiffs' Motion for Appointment of Lead

Malin v. IVAX Corp., et al., Case No. 96-1843-CIV-MORENO, Order Granting

Sec. Litig., Master File No. C97-402WD, Order Appointing Lead Plaintiffs (W.D.

Firm resume of The Olsen Law Firm.

Executed this 4th day of January, 1999, at San Francisco, California.

PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2

4 . AMENDED COMPLAINT

EXTRACTED KEY WORDS

DEFENDANTS
PLAINTIFFS
SECURITIES
REVENUE
KVAMME
EXCHANGE ACT
STOCK
REPORT
CLASS ACTION
FIRM
ANALYSTS
CLASS PERIOD
BAAB
MARKETING
PRICE
CKS REPRESENTATIVES
UNITED STATES
OLSEN LAW FIRM
SAN FRANCISCO
CALIFORNIA
CKS MANAGEMENT
COMMUNICATIONS
INDIVIDUAL DEFENDANTS
COMMON STOCK
SHAREHOLDERS
VIOLATIONS
AMENDED COMPLAINT
LERACH LLP
ACQUISITION

   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   STANLEY S. MALLISON (184191)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   415/288-4534 (fax)

   BERGER & MONTAGUE, P.C.

   TODD S. COLLINS

   JACOB A. GOLDBERG

   1622 Locust Street

   Philadelphia, PA 19103

   Telephone: 215/875-3000

   THE OLSEN LAW FIRM

   KURT B. OLSEN

   2121 "K" Street, NW

   Suite 800

   Washington, DC 20037

SNIPPETS:

HYNES & LERACH LLP

THE OLSEN LAW FIRM

Co-Lead Counsel for Plaintiffs

UNITED STATES DISTRICT COURT

CKS GROUP, INC., MARK D. KVAMME, THOMAS K.

This is a shareholders' class action on behalf of all persons, other than defendants and

During the Class Period, defendants schemed to inflate the Company's stock price by issuing

After the close of the market on Friday, November 7, 1997, the Company announced that

Plaintiffs bring this action pursuant to §§10and 20of the Securities Exchange Act of 1934, 15

Many of the acts and transactions giving rise to the violations of law complained of herein,

Further, defendant CKS has its principal place of business in this District at 10441 Bandley

In connection with the acts, conduct and other wrongs complained of herein, defendants,

Plaintiff Robert E. Wilson purchased 32 shares of CKS common stock and was damaged thereby.

The following defendants are referred to herein as the "Individual Defendants":

Defendant Mark D. Kvamme at all times relevant hereto was Chairman of the CKS Board of

Defendant Kvamme signed the Company's Annual Report on Form 10-K for the fiscal year ended

Defendant Carlton H. Baab at all times relevant hereto was Executive Vice-President, Chief

Bonus compensation payments under the Executive Bonus Program are based on attainment of

CKS's press releases, corporate reports to shareholders, and filings with the SEC were all

These communications included meetings, written financial releases, and analyst briefings,

CKS continually touted itself as an integrated marketing firm with a "new media" focus.

To enhance its focus on new media, the Company stated its policy to grow through acquisition.

That declarant is and was, at all times herein mentioned, a citizen of the United States and

That on April 9, 1999, declarant served the AMENDED COMPLAINT FOR VIOLATION OF THE SECURITIES

5 . DOCKET

EXTRACTED KEY WORDS

ENTRY
COUNSEL
LEAD PLAINTIFFS
CO-LEAD COUNSEL
APPOINTED LEAD
MOTION
CERTIFICATE
AMENDED ORDER
CHESNEY
JUDGE MAXINE
DISTRICT
DOCKET
LERACH
EDIT
DEFENDANTS
WAIVER
PUBLICATION
COMPLAINT
WILSON
JOHN TOMPKINS
ROBERT WILSON
CHESNEY GRANTING MOTION
MEMO
NON-OPPOSITION
COUNSEL WILLIAM LERACH
COUNSEL REED KATHREIN
COUNSEL TODD COLLINS
STANLEY MALLISON
DECLARATION


Docket as of February 10, 1999 (retrieved 4/1/99)

Proceedings include all events.
3:98cv4229 Wilson v. CKS Group, Inc., et al

                       U.S. District Court
  U.S. District for the Northern District of California (S.F.)

               CIVIL DOCKET FOR CASE #: 98-CV-4229

Wilson v. CKS Group, Inc., et al                            Filed: 11/05/98
Assigned to: Judge Maxine M. Chesney         Jury demand: Plaintiff
Demand: $0,000                               Nature of Suit:  850
Lead Docket: None                            Jurisdiction: Federal Question

Cause: 15:78m(a) Securities Exchange Act

(Party and Counsel List)


11/5/98  1       COMPLAINT  Summons(es) issued; Fee status pd entered on
                 11/5/98  in the amount of $ 150.00 ( Receipt No. 133106);
                 jury demand    (3:98-cv-04229) (ab)

11/5/98  2       NOTICE by Plaintiff to preserve documents  (3:98-cv-04229)
                 (ab)

11/5/98  3       ORDER RE PROCEDURE and SCHEDULE  by Judge Maxine M. Chesney
                 : Plaintiff to file requisite certificate on 11/5/98 ; Last
                 day for pltf to file copy of class action notice 11/25/98 ;
                 Proof of service to be filed by 12/21/98 ;  (cc: all
                 counsel) Plaintiff to file motion to serve as lead
                 plaintiff 60 days after publication of notice. (ab)

11/12/98 4       NOTICE by Plaintiff of publication  (3:98-cv-04229) (ab)
                 (Entry date 11/13/98)

12/22/98 5       WAIVER OF SERVICE by defendants served on 12/16/98 in
                 response to the  Request for Waiver sent on 11/12/98
                 (3:98-cv-04229) (ab) (Entry date 12/28/98)

1/4/99   6       MOTION with memorandum in support  before Judge Maxine M.
                 Chesney by Plaintiff to be appointed lead plaintiffs and
                 approval of lead plaintiffs' choice of co-lead counsel
                 with Notice set for 2/12/99 9 a.m.  (3:98-cv-04229) (ab)
                 (Entry date 01/05/99)

SNIPPETS:

Docket as of February 10,

U.S. District for the Northern District of California

(Party and Counsel List)

11/5/98 1 COMPLAINT Summonsissued;

11/5/98 3 ORDER RE PROCEDURE and SCHEDULE by Judge Maxine M. Chesney

Plaintiff to file requisite certificate on 11/5/98;

plaintiff 60 days after publication of notice.

(Entry date 11/13/98)

12/22/98 5 WAIVER OF SERVICE by defendants served on 12/16/98 in

response to the Request for Waiver sent on 11/12/98

1/4/99 6 MOTION with memorandum in support before Judge Maxine M.

approval of lead plaintiffs' choice of co-lead counsel

1/4/99 7 DECLARATION by Stanley Mallison on behalf of Plaintiff re

motion to be appointed lead plaintiffs and approval of lead

1/4/99 8 CERTIFICATE by Plaintiff's counsel Todd Collins

(Edit date 01/06/99)

1/4/99 10 CERTIFICATE by Plaintiff's counsel Reed Kathrein

1/4/99 11 CERTIFICATE by Plaintiff's counsel William Lerach

1/19/99 12 Statement by defendant in NON-Opposition to motion to be

1/29/99 13 REPLY memo by Plaintiff re motion to be appointed lead

2/8/99 14 AMENDED ORDER by Judge Maxine M. Chesney granting motion

plaintiffs' choice of co-lead counsel, Robert Wilson

and John Tompkins are appointed as lead plaintiffs,

Weiss Bershad Hynes & Lerach,

2/9/99 15 NOTICE by Plaintiff of entry of amended order

6 . COMPLAINT

EXTRACTED KEY WORDS

CEDAR
DOMINION
PLAINTIFF
BUSINESS
SECURITIES
MISLEADING
FINANCIALS
DOMINION BRIDGE
MARENGERE
CLASS ACTION
CEDAR GROUP
GROSS VIOLATIONS
MATOSSIAN
BUSINESS CONDITION
SUBSIDIARIES
FEDERAL SECURITIES LAWS
ALLEGATIONS
CLASS PERIOD
EXCHANGE ACT
COMMON STOCK
REPRESENTATIONS
PENNSYLVANIA
MISREPRESENTATIONS
FUTURE BUSINESS PROSPECTS
MARKET PRICE
ACCOUNTING PRACTICES
INDIVIDUAL DEFENDANTS
UNITED STATES
ACQUISITION


                    IN THE UNITED STATES DISTRICT COURT
                  FOR THE EASTERN DISTRICT OF PENNSYLVANIA


   ________________________________________

   JAMES B. SMITH, On Behalf Of Himself
   and Others Similarly Situated

                         Plaintiffs,

              v.

   DOMINION BRIDGE CORP. (f/k/a CEDAR
   GROUP, INC.), MICHEL L. MARENGERE and
   NICOLAS MATOSSIAN

                         Defendants.
   ________________________________________

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   CIVIL ACTION

   Case No. 96CV-7580
   (filed Oct. 7, 1996)

                          COMPLAINT - CLASS ACTION

   Plaintiff, complaining of the defendants, by his attorneys, alleges
   upon information and belief, except as to ¶8 herein, based on the
   investigation of counsel, except as to the allegations which are
   alleged on knowledge, as follows:

SNIPPETS:

Plaintiff, complaining of the defendants, by his attorneys, alleges upon information and

For over one year, defendants have concealed from plaintiffs and the investing public the

More specifically, these violations include misleading the public as to the actual quality

Defendants schemed to mislead their shareholders and the investment community as to the true tion projects; protect and enhance their positions as officers and/or directors of Cedar and the

As a result of defendants' deceptive and illegal conduct, plaintiff and other class members

Had plaintiff and the other class members been aware of the truth concerning Dominion's

This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C.

Dominion is registered in this district, specifically Conshohocken, Pennsylvania and the acts

Defendant Michel L Marengere was at all relevant times, Cedar's Chairman of the Board and

Defendant Nicolas Matossian was at all relevant times Cedar's President, Chief Financial

Defendants Marengere and Matossian (the "Individual Defendants") were at all relevant times