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1
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Government Exhibit # 2ND AMENDED CONSOLIDATED COMPLAINT
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EXTRACTED KEY WORDS
OFFERINGS COMPUTERVISION STOCK PROSPECTUS CADDS SECURITIES CUSTOMERS DEFENDANTS UNDERWRITER REVENUES PLAINTIFF PLAN MISLEADING SALES COMMON MEMBERS SECURITIES ACT COMMERCIAL SHIPMENT OFFERING PRICE MISREPRESENTATION REPRESENTATIONS MATERIALLY FALSE IPO PLAN SHEARSON HOLDINGS RECOMMENDATIONS PLAINTIFF SUBCLASS PUBLIC OFFERING VISIBILITY COMPUTER-VISION INTERNAL PLANS |
UNITED STATES
FOR THE DISTRICT OF
IN RE COMPUTERVISION SECURITIES
LITIGATION
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THIS DOCUMENT IIISLATES TO ALL ACTIONS
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SECOND AMENDED
CLASS ACTION
Plaintiffs, by their attorneys, allege upon personal knowledge as
and upon information and belief based upon an investigation by their attorneys as to all
other matters as follows:
-3
1. This is a consolidated class action on behalf
purchased Computer-vision Corporation ("Computervision" or the "Company") notes and
common stock (the `T\Totes" and "Stock") between August 14, 1992, when those
securities were first offered (the "Offerings"), and September 29, 1992, when
Computervision announced substantial losses for the third quarter of 1992 (the "Third
Quarter"), which were later quantified at approximately $88 million.
2. This Amended Complaint alleges violations
of the Securities Act of 1933 (the "Securities Act") and negligent misrepresentation based
on the prospectuses relating to the Offerings (the "Stock Prospectus" and "`Notes
Prospectus," collectively the "Prospectuses"), which contained false and misleading
I statements and omissions.
3. The Prospectuses were identical in all material respects, except for the
SNIPPETS:
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