UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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MORRIS KASSIN, on behalf :
of himself and all others : 01 Civ. 3792 (JGK)
similarly situated, :
:
Plaintiff, : CLASS ACTION COMPLAINT
:
-against- : JURY TRIAL DEMANDED
:
DIGIMARC CORPORATION, BRUCE DAVIS, :
GEOFFREY RHOADS, E.K. RANJIT, :
PHILIP J. MONEGO, SR., BRIAN V. :
GROSSI, JOHN TAYSOM and BANCBOSTON :
ROBERTSON STEPHENS, INC., :
:
Defendants. :
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Plaintiff, by and through by his attorneys, as
and for his Class Action Complaint, alleges upon personal
knowledge as to his own acts and as to all other matters
upon information and belief based upon, inter alia, the
investigation made by and through his attorneys, which
investigation included, among other things, a review of
reports filed by Digimarc Corporation ("Digimarc" or "the
Company") with the Securities and Exchange Commission or
disseminated to Digimarc's shareholders (including without
limitation, Form 10-K's, Form 10-Q's, proxy statements,
Quarterly Reports to Shareholders, the Prospectus and
Registration Statement dated December 1, 1999, (the
"Prospectus") published reports, news articles, publicly
SNIPPETS:
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Plaintiff,: CLASS ACTION COMPLAINT
DIGIMARC CORPORATION, BRUCE DAVIS,:
GROSSI, JOHN TAYSOM and BANCBOSTON:
reports filed by Digimarc Corporation ("Digimarc" or "the
disseminated to Digimarc's shareholders (including without
"Prospectus") published reports, news articles, publicly
trading volume of Digimarc's securities and interviews as
12 and 15 of the Securities Act of
77o and Sections 10and 20of the Exchange Act 15
including the preparation and dissemination
Registration Statement dated December 1,
during the Class Period (including the trading
of Digimarc stock based upon misleading information).
other wrongs complained of herein, the defendants, directly
Plaintiff purchased shares of Digimarc as
Digimarc described itself in its IPO prospectus as
percent, of Digimarc's common stock.
Defendant BancBoston Robertson Stephens,
was a lead underwriter of the Offering.
the "Individual Defendants."
press releases alleged herein to be materially false and/or
shareholders and the Offering price to the public
excessive and undisclosed commissions from
excessive commissions on transactions in other securities
Due to the undisclosed material facts
STATEMENTS AND VIOLATIONS OF SEC
including, inter alia, Regulation S-K.
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