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1
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COMPLAINT
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EXTRACTED KEY WORDS
THEREWITH QROUPS PRICES JET PRINTERS BONUSES PROXY STATEMENT MISLEADING SCHMECK ANTHONY GROH JAMES DRESDALE RICHARD |
UNITED STATES DISTRICT
NORTHERN DISTRICT OF T
DALLAS DIVISION
LORI LEMMER, On Behalf of Herself ) Civ. Action No.
and All Others Similarly Situated, ) ) COMPLAINT - CLASS ACTION
Plaintiff,
;
vs. ) COMPLAINT FOR VIOLATION
) THE SECURITIES
NU-KOTE HOLDING, INC., DAVID F. ) OF 1934
BRIGANTE, PATRICK E. HOWARD, DANIEL )
M. KERRANE, HANS PAFFHAUSEN, 1
RICHARD C. DRESDALE, JAMES H. GROH, )
JOHN P. ROCHON, C. RONALD BAIOCCHI, )
BRIAN D. FINN, HUBBARD C. HOWE and )
ANTHONY G. SCHMECK,
i
Defendants. ) Plaintiff Demands A
) Trial By Jurv
INTRODUCTION AND OVERVIEW
1. This is a class action on behalf of
common stock of Nu-kote Holding, Inc. ("Nu-kotel'
between 7/28/95 and 5/29/97, inclusive (the llClass
kote manufactures and markets impact and non-impact
products and supplies for computers, ATM machines,
etc. This action complains of a scheme and course of business
operated as 'a fraud or deceit on purchasers
Defendants knowingly made false and misleading
success of Nu-kote's 1995 acquisition of Pelikan
European seller of impact and non-impact printing
strong demand for, and market acceptance of,
Nu-kote's successful transition from sales of impact
non-impact products, including its state-of-the-art
facilities in the U.S. and Europe, its technological
development expertise that purportedly enabled
develop large numbers of new products, including
impact printer heads and related products and
for strong earnings per share (lEEPS1l) growth
while reporting false financial results, including
the 4thQ of FY96 and the lstQ, 2ndQ and 3rdQ of FY97.
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