UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
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TONY DIFATTA, : Civil Action No.
: (98-CV-70854)
Plaintiff, : (filed Feb 26, 1998)
:
-against- : CLASS ACTION COMPLAINT
:
DATA SYSTEMS NETWORK CORPORATION, :
MICHAEL W. GRIEVES, and PHILIP M. GOY, :
: JURY TRIAL DEMANDED
Defendants. :
:
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Plaintiff, Tony DiFatta, individually and on behalf of
all others similarly situated, by his attorneys, alleges
following upon information and belief, except as to allegations
specifically pertaining to plaintiff and his counsel, based upon
the facts alleged below, which are predicated upon, among other
things, a review of public filings by Data Systems Network
Corporation ("Data Systems" or the "Company") with the United
States Securities and Exchange Commission ("SEC"), press releases
issued by the Company, and media reports about the Company.
NATURE OF THE ACTION
1. Plaintiff, Tony DiFatta, brings this action as a
class action on behalf of himself and all other persons or
entities who purchased the stock of Data Systems on the open
market, during the period beginning on March 5, 1997 through
February 24, 1998, inclusive (the "Class Period"), to recover
SNIPPETS:
UNITED STATES DISTRICT COURT
DATA SYSTEMS NETWORK CORPORATION,:
Plaintiff, Tony DiFatta, individually and on behalf of
specifically pertaining to plaintiff and his counsel,
a review of public filings by Data Systems Network
States Securities and Exchange Commission,
and media reports about the Company.
entities who purchased the stock of Data Systems on the open
defendants' nondisclosures and misrepresentations of information
Section 27 of the Exchange Act and 15 U.S.C. § 78aa,
including the dissemination to the
investing public of false and misleading statements,
CLASS ACTION ALLEGATIONS
purchased shares of Data Systems common stock on the open market
omitted and/or misrepresented material facts about the
whether the market price of Data System's
include installation, consultation, training, network management,
Defendant Michael W. Grieves,
material adverse non-public information about its business,
Defendant Philip M. Goy,
with the Company, he had access to the material adverse nonpublic information about its
customers, finances, markets, management, earnings, and future
and is liable for the representations contained therein.
, including FASB Statement of Concepts No. 1, ¶¶ 34, 40,
growth, which included the making of, or the participation in the
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