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RICHARD bl. ti;IODES, *
individually and dn behalf of all :
others similarly situated,
*
P&tiff,
V.
. 1 JURY TRIAL
WILLL4.M R. CRUZ; RALPH L. :
CRUZ; OMEGA RESEARCH, : CLASS
INC.; BANCAMERICA .
ROBERTSON, STEPHENS; :
LEHMAN BROTHERS; and : CLASS
HAMBRECHT & QUIST, :
Defendants. 1.
r_____"r--_r----**______c -W------X
Plaintiff, by his attorneys, makes the following
(except as to the allegations specifically pertaining to the named
upon the facts alleged below, which are predicated upon, inter
with the Securities andExchange Commission ("SEC"), press
an investigation undertaken by plaintiffs counsel. Plaintiff
evidentiary support will exist for the allegations set forth below
discovery.
J-UFUSDI~ION AND VENUE
SNIPPETS:
The claims asserted herein arise under and pursuant to Sections 11 and 15 of the
Securities Act of 1933, as amended [15 U.S.C. 53 77k and 7701.
traceable to the initial public offering of Omega Research common stock,
Omega Research is organized under the laws of the State
of Florida and maintains its corporate headquarters in 8700 West Flagler Street, Miami,
common shares of Omega Research.
Defendants William R. Cruz and Ralph L. Cruz are, and at all relevant times were,
Each of the Individual Defendants named herein signed, personally or by attorney-in-fact, the
The Underwriter Defendants were at all times entities engaged in the business of investment
business, operations, prospects, tiancial condition and management of Omega Research, known
Plaintiff brings this action as a class action pursuant to Federal Rules of Civil
The members of the Class are so numerous that joinder of all members is
misleading representations and omissions made by or chargeable to defendants.
@> Whether the prospectus, registration statement, documents, filings, releases
In addition to the numerous materially false and misleading statements and
Decline In TradeStation Sales
called "TradeStation" which retails for approximately $2,400 per unit.
TradeStation was designed for the Windows operating system
disclosures concerning the extent to which the Individual Defendants profited from the
disclosures and to contain a complete and detailed disclosure of all material facts,
This is a classic product transition, while management did its best to keep customers in the
As a result, we are lowering our Q4:97 EPS estimate to $0.03 from $0.07 and our revenue
Omega is experiencing increasing competitive pressures, but mostly on its low end charting
contents and dissemination of the Registration Statement and the Prospectus.
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