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CONSOLIDATED AMENDED COMPLAINT
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EXTRACTED KEY WORDS
CONSULTANTS IONS TERM SUCCESS PERSONNEL OFFERING CLOSING CLASS PERIOD STATEMENTS MISLEADING MATERIALLY FALSE DEFENDANTS CAPACITIES |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
In re PERITUS SOFTWARE SERVICES, INC. ; CIVIL ACTION
SECURITIES LITIGATION 1 98-CV-10578
CONSOLIDATED AMENDED COMPLAINT
Plaintiffs, as and for their Amended Complaint,
the following upon personal knowledge as to themselves
own acts. As specified with respect to individual
below, all other allegations are based, inter alia,
investigation conducted by their attorneys, including
public filings of defendant Peritus Software Services
("Peritus'U or the t'Companyl'), reports, press releases
articles pertaining to Peritus, interviews and
former Peritus employees, Peritus customers and
consultants.
NATURE OF THE ACTION
1. Plaintiffs bring this action as a
action on behalf of themselves and all other persons or
other than defendants and certain related parties
who purchased Peritus common stock during the time
October 22, 1997 through October 26, 1998 inclusive*
Period"), under Sections lo(b) and 20(a) of the Securities
Exchange Act of 1934 (the "Exchange Act").
2. During the Class Period, defendants
false and misleading representations and omissions
Peritus's product, the market for the product, and
acquisition of Millenium Dynamics, Inc. Defendants
materially misstated Peritus's revenues,
.of
operations for each fiscal quarter during
These material misstatements artificially
stock price. At the beginning of the Class Period,
defendants' false and misleading statements
Peritus's stock traded at over $28 per share;
revealed their falsification of Peritus's
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2
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS PERITUS CORN EARNINOS DEVELO MENT DURIN HENDERSON ACCOUNT EXCHANGE ACT MEMBERS NASDAQ EXCHANGE PERITUS SOFTWARE SERVICES CATALANO DOUGLAS CHAN |
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UNITED STATES DISTRICT COURT
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DISTRICT OF MASSACHUSETTS
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ROBERT DOWNEY, CIVIL
on behalf of himself and
all others similarly situated, :
Plaintiff, ; g&~~~~~Gy
CLASS
-against- FOR
FEDERAL
DOMINIC K. CHAN, DOUGLAS A.
CATALANO, ALLEN K. DEARY,
and PERITUS SOFTWARE
SERVICES, Inc.,
JURYTRIAL
Defendants. :
Plaintiff, as and for his complaint,
r
upon personal knowledge as to himself and
upon
information and belief as to all other
information and belief are based, inter
- alia
conducted by his attorneys, including a
ings
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