VERSANT OBJECT TECHNOLOGY CLASS ACTION LITIGATION

DECLARE
PLAINTIFFS
LERACH LLP
JUDICIAL NOTICE
CALIFORNIA
SAN DIEGO
COMMISSIONER
EXHIBIT
ACT
REQUEST
AUTHORITY
SECURITIES LITIGATION
COURT
NORTHERN DISTRICT
UNITED STATES
KATHREIN
HYNES
MILBERG WEISS BERSHAD
PAUL
CHAIRMAN
LEGISLATIVE HISTORY
STANDARDS
PRESIDENT
CO-LEAD COUNSEL
NICHOLAS
BLAIR
BASSER
BACINE
RODOS


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE

   STEPHEN R. BASSER (121590)

   BLAIR A. NICHOLAS (178428)

   600 West Broadway, Suite 1700

   San Diego, CA 92101

   Telephone: 619/230-0800

   Co-Lead Counsel for Plaintiffs

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   In re VERSANT OBJECT TECHNOLOGY

   CORP. SECURITIES LITIGATION

SNIPPETS:

MILBERG WEISS BERSHAD

HYNES & LERACH LLP

San Diego, CA 92101

- and -REED R. KATHREIN

San Francisco, CA 94108

BARRACK, RODOS & BACINE

STEPHEN R. BASSER

BLAIR A. NICHOLAS

Co-Lead Counsel for Plaintiffs

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

REQUEST FOR JUDICIAL NOTICE

On November 3, 1998, President Clinton signed into law the Securities Litigation Uniform

The legislative history of the Act directly addresses the pleading standards under the

Plaintiffs submit the following recent authority in further support of their opposition to

Exhibit 1: H.R. Conf.

PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2

That on November 12, 1998, declarant served the PLAINTIFFS' STATEMENT OF RECENT AUTHORITY AND

I declare under penalty of perjury that the foregoing is true and correct.

2 . REPLY MEMORANDUM IN SUPPORT OF MOTION TO DISMISS 2

EXTRACTED KEY WORDS

DEFENDANTS
ALLEGATIONS
SCIENTER
PLEAD
PLAINTIFFS FAIL
COMPLAINT
COURT
DISMISS
CIR
LITIG
MOTION
VERSANT
SUPP
INTERNAL REPORTS
SUPPORT
TECHNOLOGY
SECURITIES
GAAP VIOLATIONS
AUTHORITIES
LAWRENCE
SILICON GRAPHICS
PRE-REFORM ACT
PARTICULARITY
TRANSFER BINDER
CCH
NEGATIVE INTERNAL REPORTS
NORTHERN DISTRICT
CALIFORNIA
STOCK SALES


   MELVIN R. GOLDMAN (BAR NO. 34097)
   JORDAN ETH (BAR NO. 121617)
   LAWRENCE R. KATZIN (BAR NO. 142885)
   JILL D. FAIRBROTHER (BAR NO. 193620)
   MORRISON & FOERSTER LLP
   425 Market Street
   San Francisco, California 94105-2482
   Telephone: (415) 268-7000

   Attorneys for Defendants
   VERSANT CORP. (sued herein as VERSANT
   OBJECT TECHNOLOGY CORP.), DAVID
   BANKS, JAMES R. LOCHRY, LAWRENCE J.
   PULKOWNIK, GEORGE C. FRANZEN,
   RONALD KOPECK, GARY RHEA, AND
   LAWRENCE K. ORR

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

                              OAKLAND DIVISION

   In re VERSANT OBJECT TECHNOLOGY
   CORP. SECURITIES LITIGATION
   _____________________________________
   This Document Relates To:
   ALL ACTIONS
   _____________________________________

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   Master File No. C-98-0299-CW
   DEFENDANTS' REPLY
   MEMORANDUM IN SUPPORT OF

SNIPPETS:

VERSANT CORP. (sued herein as VERSANT

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

In re VERSANT OBJECT TECHNOLOGY

DEFENDANTS' REPLY MEMORANDUM IN SUPPORT OF MOTION TO DISMISS THE CONSOLIDATED AMENDED

TABLE OF AUTHORITIES

Generic Allegations of "Negative Internal Reports" Do Not Plead Scienter

Allegations of GAAP Violations Do Not Plead Scienter

PLAINTIFFS' NON-ACCOUNTING ALLEGATIONS FAIL TO STATE A CLAIM

Plaintiffs Fail to Plead Falsity With Particularity

(1998 Transfer Binder), Fed.

Sec. L. Rep. (CCH) ¶ 90,108 (C.D.

137 F.3d 616 (9th Cir.

F. Supp.

In re Bally Manufacturing Sec. Litig.,

In re Silicon Graphics, Inc.

plaintiffs claim that the superficial allegations of their complaint are sufficient.

plaintiffs claim that the Court cannot resolve this issue on a motion to dismiss.

Plaintiffs do not even discuss the Ninth Circuit and Northern District cases that defendants

Fecht did not address scienter at all; it is a pre-Reform Act case, and before the Reform

Publicly disclosed information cannot form the basis of a securities fraud claim.

3 . REPLY MEMORANDUM IN SUPPORT OF MOTION TO DISMISS

EXTRACTED KEY WORDS

DEFENDANTS
ALLEGATIONS
FACTS
PLEAD
VERSANT
COURTS
SCIENTER
COMPLAINT
PLAINTIFFS FAIL
ORR
DISTRICT
SECURITIES
INFERENCE
JUDGE
CIR
FACTS GIVING RISE
REFORM ACT
AUTHORITIES
PARTICULARITY
VAGUE STATEMENTS
ACCURATE STATEMENTS
LAWRENCE
VERSANT OBJECT TECHNOLOGY
INTERNAL REPORTS
LEXIS
ACCOUNTING
GARY RHEA
JORDAN ETH
BAR


   MELVIN R. GOLDMAN (BAR NO. 34097)
   JORDAN ETH (BAR NO. 121617)
   CRAIG D. MARTIN (BAR NO. 168195)
   MORRISON & FOERSTER LLP
   425 Market Street
   San Francisco, California 94105-2482
   Telephone: (415) 268-7000

   Attorneys for Defendants
   VERSANT OBJECT TECHNOLOGY CORP.,
   DAVID BANKS, JAMES R. LOCHRY, LAWRENCE J.
   PULKOWNIK, GEORGE C. FRANZEN, RONALD
   KOPECK, GARY RHEA, and LAWRENCE K. ORR

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   In re VERSANT OBJECT TECHNOLOGY
   CORP. SECURITIES LITIGATION

   _______________________________________

   This Document Relates To:

   ALL ACTIONS.

   _______________________________________

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   Master File No. C-98-0299-CW

   DEFENDANTS' REPLY
   MEMORANDUM IN SUPPORT OF
   MOTION TO DISMISS

SNIPPETS:

MELVIN R. GOLDMAN (BAR NO. 34097) JORDAN ETH CRAIG D. MARTIN MORRISON & FOERSTER LLP

KOPECK, GARY RHEA, and LAWRENCE K. ORR

NORTHERN DISTRICT OF CALIFORNIA

In re VERSANT OBJECT TECHNOLOGY

DEFENDANTS' REPLY MEMORANDUM IN SUPPORT OF MOTION TO DISMISS CONSOLIDATED AMENDED COMPLAINT

Time: 10:00 a.m. Judge: Hon.

TABLE OF AUTHORITIES

PLAINTIFFS PLEAD NO FACTS GIVING RISE TO A "STRONG INFERENCE" OF SCIENTER.

PLAINTIFFS' NON-ACCOUNTING ALLEGATIONS DO NOT STATE A CLAIM.

Accurate Statements of Fact And Vague Statements Of Optimism Are Not Actionable.

Plaintiffs Fail To Plead Facts Showing That Any Statement Was False When Made.

PLAINTIFFS' ACCOUNTING ALLEGATIONS DO NOT STATE A CLAIM.

PLAINTIFFS FAIL TO STATE A CLAIM AGAINST OUTSIDE DIRECTOR ORR.

Predictably, this announcement resulted in a punishing drop in Versant's stock price and, of

Plaintiffs claim that they have pleaded a strong inference of scienter by alleging a

But alone or in combination, these allegations do not come close to satisfying the Reform

Even before the Reform Act, however, the Ninth Circuit required plaintiffs to allege specific

defendants respectfully request that this Court dismiss the Consolidated Amended Complaint

See, e.g., In re Worlds of Wonder Sec. Litig., 35 F.3d 1407, 1419 (9th Cir.

Plaintiffs argue that they plead with particularity by reciting press releases concerning

LEXIS at *10 ("there can be no assurance that such estimates.

MELVIN R. GOLDMAN JORDAN ETH CRAIG D. MARTIN MORRISON & FOERSTER LLP

4 . MOTION TO DISMISS CONSOLIDATED AMENDED COMPLAINT

EXTRACTED KEY WORDS

VERSANT
DEFENDANTS
COMPLAINT
ACT
MARTIN
COURT
SECURITIES
ORR
FACTS
BANKS
PLAINTIFFS ALLEGE
REVENUE
ALLEGATIONS
LITIG
MOTION
PLAINTIFFS FAIL
CCH
VERSANT OBJECT TECHNOLOGY
LEXIS
ACCOUNTING
CLASS PERIOD
TRANSFER BINDER
SUPPORTING
MARTIN DECL
STOCK PRICE
OBLIGATIONS
GIVING RISE
REFORM ACT
AUTHORITIES


   Melvin R. Goldman (Bar No. 34097)
   Jordan Eth (Bar No. 121617)
   Craig D. Martin (Bar No. 168195)
   Morrison & Foerster LLP
   425 Market Street
   San Francisco, California 94105-2482
   Telephone: (415) 268-7000

   Attorneys for Defendants
   VERSANT OBJECT TECHNOLOGY CORP., DAVID
   BANKS, JAMES R. LOCHRY, LAWRENCE J. PULKOWNIK,
   GEORGE C. FRANZEN, RONALD KOPECK, GARY RHEA, AND
   LAWRENCE K. ORR

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   In re VERSANT OBJECT TECHNOLOGY
   CORP. SECURITIES LITIGATION

   _______________________________________

   This Document Relates To:

   ALL ACTIONS.

   _______________________________________

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   Master File No. C-98-0299-CW

SNIPPETS:

UNITED STATES DISTRICT COURT

In re VERSANT OBJECT TECHNOLOGY

DEFENDANTS' NOTICE OF MOTION AND MOTION TO DISMISS CONSOLIDATED AMENDED COMPLAINT FOR

TO PLAINTIFFS AND THEIR ATTORNEYS OF RECORD:

Please take notice that on September 25, 1998, at 9:00 a.m., or as soon thereafter as the the Private Securities Litigation Reform Act of 1995, to dismiss with prejudice plaintiffs'

This motion is based on this Notice of Motion and Motion and supporting Memorandum of Points

Do plaintiffs plead that Versant misled investors about its future financial performance

Do plaintiffs plead that Versant fraudulently reported its second and third quarter revenue

PLAINTIFFS' ACCOUNTING ALLEGATIONS FAIL TO STATE A CLAIM.

PLAINTIFFS FAIL TO PLEAD FACTS GIVING RISE TO A "STRONG INFERENCE" OF SCIENTER.

(1987 Transfer Binder)

Sec. L. Rep. (CCH) ¶ 93,289 (N.D.

LEXIS 6930 (S.D.

In re Apple Computer Sec. Litig.,

First, on the non-accounting claims, although plaintiffs allege that Versant misled the

Even before the Private Securities Litigation Reform Act, plaintiffs could not base a claim

On the first day of the class period, Versant's CEO went so far as to tell investors that

Plaintiffs' allegations that revenues from two transactions were improperly recognized

Plaintiffs allege that in the Spring of 1997, defendants launched a plan to inflate Versant's

(Martin Decl., Ex.

5 . MOTION TO DISMISS COMPLAINT B

EXTRACTED KEY WORDS

DEFENDANTS
VERSANT
COMPLAINT
ACT
SECURITIES
COURT
ORR
MARTIN
FACTS
BANKS
PLAINTIFFS ALLEGE
MOTION
COMPL
STOCK
REVENUE
ALLEGATIONS
VERSANT OBJECT TECHNOLOGY
PLAINTIFFS FAIL
SUPPORTING MEMORANDUM
CCH
PLAINTIFFS CLAIM
NEGATIVE INTERNAL REPORTS
INFERENCE
VIOLATION
DISTRICT COURT
RONALD KOPECK
PULKOWNIK
DAVID BANKS
CALIFORNIA


   MELVIN R. GOLDMAN (BAR NO. 34097)
   JORDAN ETH (BAR NO. 121617)
   CRAIG D. MARTIN (BAR NO. 168195)
   MORRISON & FOERSTER LLP
   425 Market Street
   San Francisco, California 94105-2482
   Telephone: (415) 268-7000

   Attorneys for Defendants
   VERSANT OBJECT TECHNOLOGY CORP.,
   DAVID BANKS, JAMES R. LOCHRY, LAWRENCE
   J. PULKOWNIK, GEORGE C. FRANZEN,
   RONALD KOPECK, GARY RHEA, and
   LAWRENCE K. ORR

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   RICHARD GEFFEN, et al., On Behalf of
   Themselves and All Others Similarly Situated,

                         Plaintiffs,

              v.

   VERSANT OBJECT TECHNOLOGY CORP.,
   et al.,

                         Defendants.
   ______________________________________

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   No. C-98-0440-MMC

SNIPPETS:

Attorneys for Defendants

LAWRENCE K. ORR

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

VERSANT OBJECT TECHNOLOGY CORP.,

DEFENDANTS' NOTICE OF MOTION AND MOTION TO DISMISS COMPLAINT FOR VIOLATION OF THE SECURITIES

TO PLAINTIFFS AND THEIR ATTORNEYS OF RECORD:

Please take notice that on May 1, 1998, at 9:00 a.m., or as soon thereafter as the matter may e and the Private Securities Litigation Reform Act of 1995, to dismiss with prejudice plaintiffs'

This motion is based on this Notice of Motion and Motion and supporting Memorandum of Points

Do plaintiffs' claims fail for the additional reason that Versant disclosed the exact risks

Do plaintiffs allege with particularity claims based on analyst statements where plaintiffs

Have plaintiffs alleged facts showing a "strong interference" of "actual knowledge" that

PLAINTIFFS FAIL TO PLEAD THAT VERSANT MISREPRESENTED ANY FACT.

PLAINTIFFS FAIL TO PLEAD FACTS GIVING RISE TO A "STRONG INFERENCE" OF SCIENTER.

Plaintiffs filed this action because Versant's stock price declined after the Company

The Ninth Circuit has never permitted cases making these allegations to proceed.

(Compl., ¶ 41.)

Rather, plaintiffs allege that Versant's accurate statements led the market to expect an even

Sec. L. Rep (CCH) ¶ 99,465 at 97,079-81 (N.D.

6 . MOTION TO DISMISS COMPLAINT

EXTRACTED KEY WORDS

DEFENDANTS
VERSANT
COMPLAINT
ACT
COURT
SECURITIES
ORR
MARTIN
LITIG
MOTION
BANKS
FACTS
PLAINTIFF ALLEGES
COMPL
CIR
CCH
VERSANT OBJECT TECHNOLOGY
ALLEGATIONS
TRANSFER BINDER
PLAINTIFF FAILS
SUPPORTING
PLAINTIFF CLAIMS
INFERENCE
PARTICULARITY
AUTHORITIES
VIOLATION
DISTRICT COURT
PULKOWNIK
CALIFORNIA


   MELVIN R. GOLDMAN (BAR NO. 34097)
   JORDAN ETH (BAR NO. 121617)
   CRAIG D. MARTIN (BAR NO. 168195)
   MORRISON & FOERSTER LLP
   425 Market Street
   San Francisco, California 94105-2482
   Telephone: (415) 268-7000

   Attorneys for Defendants
   VERSANT OBJECT TECHNOLOGY CORP., DAVID
   BANKS, JAMES R. LOCHRY, LAWRENCE J.
   PULKOWNIK, GEORGE C. FRANZEN, RONALD
   KOPECK, GARY RHEA, and LAWRENCE K. ORR

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   STEVEN WILKES, et al., On Behalf of Himself
   and All Others Similarly Situated,

                         Plaintiff,

              v.

   VERSANT OBJECT TECHNOLOGY CORP.,
   et al.,

                         Defendants.
   _______________________________________

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   No. C-98-0299-CW

SNIPPETS:

Attorneys for Defendants

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

VERSANT OBJECT TECHNOLOGY CORP.,

DEFENDANTS' NOTICE OF MOTION AND MOTION TO DISMISS COMPLAINT FOR VIOLATION OF THE SECURITIES

TO PLAINTIFF AND HIS ATTORNEY OF RECORD:

Please take notice that on May 1, 1998, at 10:00 a.m., or as soon thereafter as the matter ivate Securities Litigation Reform Act of 1995, to dismiss with prejudice plaintiff's Class Action

This motion is based on this Notice of Motion and Motion and supporting Memorandum of Points

Does plaintiff meet the Ninth Circuit's requirement that he plead with particularity

Has plaintiff alleged facts showing a "strong inference" of "actual knowledge" that Versant

PLAINTIFF FAILS TO PLEAD THAT VERSANT MISREPRESENTED ANY FACT.

Versant Disclosed The Precise Risks Plaintiff Claims Were Omitted.

14 F.3d 449 (9th Cir.

Cooper v. Hwang, (Current Transfer Binder) Fed.

Sec. L. Rep. (CCH) ¶ 93,289 (N.D.

In re Apple Computer Sec. Litig.,

The Ninth Circuit has never permitted cases making these allegations to proceed.

(Compl., ¶ 41.)

7 . MOTION TO DISMISS AMENDED COMPLAINT

EXTRACTED KEY WORDS

DEFENDANTS
VERSANT
ACT
COMPLAINT
COURT
FAIRBROTHER
ORR
SECURITIES
MOTION
LITIG
CIR
SALES
SCIENTER
BANKS
PLAINTIFFS ALLEGE
ALLEGATIONS
CCH
TRANSFER BINDER
RONALD KOPECK
VERSANT OBJECT TECHNOLOGY
ACCOUNTING
NEGATIVE INTERNAL REPORTS
UNITED STATES DISTRICT
CALIFORNIA
CLASS PERIOD
SILICON GRAPHICS
PARTICULARITY
REFORM ACT
AUTHORITIES


   MELVIN R. GOLDMAN (BAR NO. 34097)
   JORDAN ETH (BAR NO. 121617)
   LAWRENCE R. KATZIN (BAR NO. 142885)
   JILL D. FAIRBROTHER (BAR NO. 193620)
   MORRISON & FOERSTER LLP
   425 Market Street
   San Francisco, California 94105-2482
   Telephone: (415) 268-7000

   Attorneys for Defendants
   VERSANT CORP. (sued herein as VERSANT
   OBJECT TECHNOLOGY CORP.), DAVID BANKS,
   JAMES R. LOCHRY, LAWRENCE J. PULKOWNIK,
   GEORGE C. FRANZEN, RONALD KOPECK, GARY
   RHEA, AND LAWRENCE K. ORR

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   In re VERSANT OBJECT TECHNOLOGY
   CORP. SECURITIES LITIGATION
   _____________________________________
   This Document Relates To:
   ALL ACTIONS.
   _____________________________________

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   Master File No. C-98-0299-CW

   DEFENDANTS' NOTICE OF MOTION
   AND MOTION TO DISMISS
   CONSOLIDATED AMENDED

SNIPPETS:

VERSANT CORP. (sued herein as VERSANT

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

In re VERSANT OBJECT TECHNOLOGY

DEFENDANTS' NOTICE OF MOTION AND MOTION TO DISMISS CONSOLIDATED AMENDED COMPLAINT FOR

TO PLAINTIFFS AND THEIR ATTORNEYS OF RECORD:

This motion is based on this Notice of Motion and Motion and supporting Memorandum of Points

Do allegations of unnamed, undated "negative internal reports;" generic allegations of a

Do plaintiffs' accounting claims fail for the additional reasons that: plaintiffs do not

PLAINTIFFS PLEAD NO FACTS GIVING RISE TO A "STRONG INFERENCE" OF SCIENTER

(1987 Transfer Binder)

Sec. L. Rep. (CCH) ¶ 93,289 (N.D.

137 F.3d 616 (9th Cir.

Sec. Litig.,

In re Silicon Graphics, Inc.

Plaintiffs allege the following fraud: In April 1997, six of Versant's officers and one

Congress passed the Reform Act to prevent conclusory and speculative claims such as these

A at A 06).1 At the time of the interview, Versant's stock was trading at $5 1/4 per share,2

8 . MOTION TO CONSOLIDATE CASES FOR ALL PURPOSES

EXTRACTED KEY WORDS

DEFENDANTS
COURT
MOTION
VERSANT
PLAINTIFFS
SAN FRANCISCO
DISTRICT
LAW
COMMON QUESTIONS
PURPOSES
ARNOUVILLE
LUU
COMPLAINT
ALLEGES
ACT
UNITED STATES
FEDERAL RULES
PURSUANT
LEAD PLAINTIFF
LAWSUITS
VERSANT OBJECT
CALIFORNIA
LERACH LLP
DECLARE
GROWTH
RELATED ACTIONS
PENDING
SECURITIES
CIVIL PROCEDURE


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE

   STEPHEN R. BASSER (121590)

   600 West Broadway, Suite 1700

   San Diego, CA 92101

   Telephone: 619/230-0800

   (Proposed) Co-Lead Counsel for Plaintiffs

   and Attorneys for Plaintiffs in

   Geffen, No. C-98-0440-MMC;

   Luu, No. C-98-0969-SBA;

   Arnouville, No. C-98-1079-FMS

   (Additional counsel appear on signature page.)

SNIPPETS:

HYNES & LERACH LLP

San Francisco, CA 94108

Co-Lead Counsel for Plaintiffs

Luu, No. C-98-0969-SBA;

Arnouville, No. C-98-1079-FMS

NORTHERN DISTRICT OF CALIFORNIA

NOTICE OF MOTION AND MOTION

THIS COURT SHOULD CONSOLIDATE THE LAWSUITS FOR PURPOSES OF EFFICIENCY

PLEASE TAKE NOTICE that, on May 15, 1998 at 10:00 a.m. in the Courtroom of the Honorable

The basis for the motion is that these actions are substantially identical, involve the same

Four securities fraud class action lawsuits against the same defendants are presently pending

Wilkes v. Versant Object

Because these actions are substantially identical and raise common questions of fact and law,

Each of these cases alleges claims on a class-wide basis on behalf of purchasers of the

Each case alleges that Versant and its senior executive officers disseminated materially

Each of the four actions allege violations of §§10and 20of the Securities Exchange Act of

See Geffen complaint, ¶102; Luu complaint, ¶102; Arnouville complaint, ¶102.

When actions involving a common question of law or fact are pending before the court, it may

THE STATUTE REQUIRES THAT THE QUESTION OF CONSOLIDATION BE DECIDED PRIOR TO THE DETERMINATION

Movants ask the Court to resolve the consolidation motion as soon as practicable and

I declare under penalty of perjury that the foregoing is true and correct.

9 . MOTION TO CONSOLIDATE CASES

EXTRACTED KEY WORDS

DEFENDANTS
COURT
MOTION
VERSANT
SAN FRANCISCO
DISTRICT
PLAINTIFFS
LAW
COMMON QUESTIONS
PURPOSES
COMPLAINT
ALLEGES
ACT
ARNOUVILLE
LUU
UNITED STATES
FEDERAL RULES
PURSUANT
LEAD PLAINTIFF
LAWSUITS
VERSANT OBJECT
CALIFORNIA
YORK
LERACH LLP
DECLARE
GROWTH
PENDING
SECURITIES
CIVIL PROCEDURE

   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE

   STEPHEN R. BASSER (121590)

   BLAIR A. NICHOLAS (178428)

   600 West Broadway, Suite 1700

   San Diego, CA 92101

   Telephone: 619/230-0800

   BERNSTEIN LIEBHARD & LIFSHITZ

   MEL E. LIFSHITZ

   274 Madison Avenue

   New York, NY 10016

   Telephone: 212/779-1414

SNIPPETS:

HYNES & LERACH LLP

San Francisco, CA 94108

New York, NY 10016

Attorneys for Plaintiffs

NORTHERN DISTRICT OF CALIFORNIA

NOTICE OF MOTION AND MOTION

THIS COURT SHOULD CONSOLIDATE THE LAWSUITS FOR PURPOSES OF EFFICIENCY

PLEASE TAKE NOTICE that, on May 15, 1998 at 10:00 a.m. in the Courtroom of the Honorable

The basis for the motion is that these actions are substantially identical, involve the same

Four securities fraud class action lawsuits against the same defendants are presently pending

Wilkes v. Versant Object

Luu v. Versant Object

Arnouville v. Versant Object

Because these actions are substantially identical and raise common questions of fact and law,

Each of these cases alleges claims on a class-wide basis on behalf of purchasers of the

Each case alleges that Versant and its senior executive officers disseminated materially

Each of the four actions allege violations of §§10and 20of the Securities Exchange Act of

See Geffen complaint, ¶102; Luu complaint, ¶102; Arnouville complaint, ¶102.

When actions involving a common question of law or fact are pending before the court, it may

THE STATUTE REQUIRES THAT THE QUESTION OF CONSOLIDATION BE DECIDED PRIOR TO THE DETERMINATION

I declare under penalty of perjury that the foregoing is true and correct.

10 . MOTION TO CONSOLIDATE

EXTRACTED KEY WORDS

DEFENDANTS
COURT
MOTION
VERSANT
DISTRICT
PLAINTIFF
COMMON QUESTIONS
PURPOSES
SAN FRANCISCO
COMPLAINT
ALLEGES
LAW
LUU
ACT
ARNOUVILLE
UNITED STATES
FEDERAL RULES
PURSUANT
LEAD PLAINTIFF
LAWSUITS
VERSANT OBJECT
CALIFORNIA
LERACH LLP
DECLARE
GROWTH
RELATED ACTIONS
PENDING
SECURITIES
CIVIL PROCEDURE


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   COHEN, MILSTEIN, HAUSFELD

   & TOLL, P.L.L.C.

   STEVEN J. TOLL

   KRISTOPHER A. KINCADE

   999 Third Avenue, Suite 3600

   Seattle, WA 98104

   Telephone: 206/521-0080

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

                              OAKLAND DIVISION

SNIPPETS:

HYNES & LERACH LLP

San Francisco, CA 94108

Attorneys for Plaintiff

NORTHERN DISTRICT OF CALIFORNIA

NOTICE OF MOTION AND MOTION

THIS COURT SHOULD CONSOLIDATE THE LAWSUITS FOR PURPOSES OF EFFICIENCY

PLEASE TAKE NOTICE that, on May 15, 1998 at 10:00 a.m. in the Courtroom of the Honorable

Court, 1301 Clay Street, Oakland, California 94612, Richard Geffen, Tammy Newman, Louis Luu

The basis for the motion is that these actions are substantially identical, involve the same

Four securities fraud class action lawsuits against the same defendants are presently pending

Wilkes v. Versant Object

Arnouville v. Versant Object

Because these actions are substantially identical and raise common questions of fact and law,

Each of these cases alleges claims on a class-wide basis on behalf of purchasers of the

Each case alleges that Versant and its senior executive officers disseminated materially

Each of the four actions allege violations of §§10and 20of the Securities Exchange Act of

See Geffen complaint, ¶102; Luu complaint, ¶102; Arnouville complaint, ¶102.

When actions involving a common question of law or fact are pending before the court, it may

THE STATUTE REQUIRES THAT THE QUESTION OF CONSOLIDATION BE DECIDED PRIOR TO THE DETERMINATION

Movants ask the Court to resolve the consolidation motion as soon as practicable and

I declare under penalty of perjury that the foregoing is true and correct.

11 . MOTION AND MEMORANDUM IN SUPPORT OF MOTION TO BE APPOINTED

EXTRACTED KEY WORDS

VERSANT
DEFENDANTS
COUNSEL
MOTION
COURT
GRANT
GEFFEN GROUP
SAN FRANCISCO
LEAD PLAINTIFFS
CLASS MEMBERS
VERSANT OBJECT
LERACH LLP
MILBERG WEISS
VERSANT STOCK
UNITED STATES DISTRICT
UNITED STATES
EXCHANGE ACT
AUTHORITIES
MEMORANDUM
CALIFORNIA
SQUIRE
LIFSHITZ
MILBERG WEISS BERSHAD
APPOINTED LEAD PLAINTIFFS
FEDERAL RULES
SECURITIES EXCHANGE ACT
VERSANT OBJECT TECHNOLOGY
LOUIS SANDLER
KATHREIN


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE

   STEPHEN R. BASSER (121590)

   BLAIR A. NICHOLAS (178428)

   600 West Broadway, Suite 1700

   San Diego, CA 92101

   Telephone: 619/230-0800

   BERNSTEIN LIEBHARD & LIFSHITZ

   MEL E. LIFSHITZ

   274 Madison Avenue

   New York, NY 10016

   Telephone: 212/779-1414

SNIPPETS:

- and -REED R. KATHREIN

San Francisco, CA 94108

BERNSTEIN LIEBHARD & LIFSHITZ

JEFFREY H. SQUIRE

LOUIS SANDLER

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND

MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO

§21DOF THE SECURITIES EXCHANGE ACT OF 1934

SELECTION OF CO-LEAD COUNSEL

THE GEFFEN GROUP SHOULD BE APPOINTED AS LEAD PLAINTIFFS

The Geffen Group Has Complied With The PSLRA And Is Entitled To Be Appointed Lead Plaintiffs

PLEASE TAKE NOTICE that, on May 15, 1998, at 10:00 a.m. or as soon thereafter as this matter

This motion is based on this notice of motion and memorandum of points and authorities, the

The Wilkes actionwas brought on January 26, 1998 as a class action for securities fraud

Thereafter, three additional complaints were filed in this district on behalf of Geffen,

Wilkes v. Versant Object

Grant Decl., Ex.

The Geffen Group now requests, pursuant to §21Dof the Exchange Act, that the Court appoint it

The members of the Geffen Group purchased their Versant stock during the Class Period and

The Private Securities Litigation Reform Act establishes a procedure for the appointment of a

The plaintiff in the first action that is filed must publish, within 20 days of filing the

, plaintiffs in the three related actions, together with an additional 40 purchasers of

12 . MOTION AND MEMO TO BE APPOINTED

EXTRACTED KEY WORDS

VERSANT
DEFENDANTS
CO-LEAD COUNSEL
EXCHANGE ACT
MOTION
COURT
GRANT
APPOINTED LEAD PLAINTIFFS
SECURITIES EXCHANGE ACT
GEFFEN GROUP
APPOINTMENT
SAN FRANCISCO
CLASS MEMBERS
SELECTION
PLAINTIFFS PURSUANT
VERSANT OBJECT
LERACH LLP
MILBERG WEISS
VERSANT STOCK
UNITED STATES DISTRICT
UNITED STATES
AUTHORITIES
MEMORANDUM
CALIFORNIA
TOLL
MILBERG WEISS BERSHAD
FEDERAL RULES
VERSANT OBJECT TECHNOLOGY
KATHREIN


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   COHEN, MILSTEIN, HAUSFELD

   & TOLL, P.L.L.C.

   STEVEN J. TOLL

   KRISTOPHER A. KINCADE

   999 Third Avenue, Suite 3600

   Seattle, WA 98104

   Telephone: 206/521-0080

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

                              OAKLAND DIVISION

SNIPPETS:

- and -REED R. KATHREIN

San Francisco, CA 94108

& TOLL, P.L.L.C.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND

MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO

§21DOF THE SECURITIES EXCHANGE ACT OF 1934

SELECTION OF CO-LEAD COUNSEL

THE GEFFEN GROUP SHOULD BE APPOINTED AS LEAD PLAINTIFFS

The Geffen Group Has Complied With The PSLRA And Is Entitled To Be Appointed Lead Plaintiffs

Counsel Selected By The Geffen Group Are Qualified, Experienced Class Counsel And Should Be

PLEASE TAKE NOTICE that, on May 15, 1998, at 10:00 a.m. or as soon thereafter as this matter

This motion is based on this notice of motion and memorandum of points and authorities, the

The Wilkes actionwas brought on January 26, 1998 as a class action for securities fraud

Thereafter, three additional complaints were filed in this district on behalf of Geffen,

Wilkes v. Versant Object

Grant Decl., Ex.

The notice advised class members that they had sixty days from January 29, 1998 to bring a

The Geffen Group now requests, pursuant to §21Dof the Exchange Act, that the Court appoint it

The members of the Geffen Group purchased their Versant stock during the Class Period and

The Private Securities Litigation Reform Act establishes a procedure for the appointment of a

The plaintiff in the first action that is filed must publish, within 20 days of filing the

OF MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO §21DOF

, plaintiffs in the three related actions, together with an additional 40 purchasers of

13 . MOTION AND MEMO IN SUPPORT OF MOTION TO BE APPOINTED

EXTRACTED KEY WORDS

VERSANT
CO-LEAD COUNSEL
DEFENDANTS
EXCHANGE ACT
MOTION
COURT
GRANT
APPOINTED LEAD PLAINTIFFS
SECURITIES EXCHANGE ACT
GEFFEN GROUP
SAN FRANCISCO
WILKES
CLASS MEMBERS
PLAINTIFFS PURSUANT
VERSANT OBJECT
ARNOUVILLE
LERACH LLP
MILBERG WEISS
VERSANT STOCK
UNITED STATES DISTRICT
UNITED STATES
AUTHORITIES
MEMORANDUM
CALIFORNIA
ATTORNEYS
SAN DIEGO
MILBERG WEISS BERSHAD
FEDERAL RULES
VERSANT OBJECT TECHNOLOGY


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE

   STEPHEN R. BASSER (121590)

   600 West Broadway, Suite 1700

   San Diego, CA 92101

   Telephone: 619/230-0800

   (Proposed) Co-Lead Counsel for Plaintiffs

   and Attorneys for Plaintiffs in

   Geffen, No. C-98-0440-MMC;

   Luu, No. C-98-0969-SBA;

   Arnouville, No. C-98-1079-FMS

   (Additional counsel appear on signature page.)

SNIPPETS:

San Diego, CA 92101

San Francisco, CA 94108

Co-Lead Counsel for Plaintiffs

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND

MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO

§21DOF THE SECURITIES EXCHANGE ACT OF 1934

THE GEFFEN GROUP SHOULD BE APPOINTED AS LEAD PLAINTIFFS

The Geffen Group Has Complied With The PSLRA And Is Entitled To Be Appointed Lead Plaintiffs

THE PARTIES AND THEIR ATTORNEYS OF RECORD

PLEASE TAKE NOTICE that, on May 15, 1998, at 10:00 a.m. or as soon thereafter as this matter

This motion is based on this notice of motion and memorandum of points and authorities, the

The Wilkes actionwas brought on January 26, 1998 as a class action for securities fraud

Thereafter, three additional complaints were filed in this district on behalf of Geffen,

Wilkes v. Versant Object

Grant Decl., Ex.

The Geffen Group now requests, pursuant to §21Dof the Exchange Act, that the Court appoint it

The members of the Geffen Group purchased their Versant stock during the Class Period and

The Private Securities Litigation Reform Act establishes a procedure for the appointment of a

The plaintiff in the first action that is filed must publish, within 20 days of filing the

OF MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO §21DOF

, plaintiffs in the three related actions, together with an additional 40 purchasers of

14 . MEMORANDUM IN SUPPORT OF MOTION TO CONSOLIDATE

EXTRACTED KEY WORDS

DEFENDANTS
COURT
MOTION
VERSANT
DISTRICT
PLAINTIFF
COMMON QUESTIONS
PURPOSES
SAN FRANCISCO
COMPLAINT
ALLEGES
LAW
ARNOUVILLE
ACT
LUU
UNITED STATES
FEDERAL RULES
PURSUANT
LEAD PLAINTIFF
LAWSUITS
VERSANT OBJECT
CALIFORNIA
LERACH LLP
DECLARE
GROWTH
RELATED ACTIONS
PENDING
SECURITIES
CIVIL PROCEDURE


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BERGER & MONTAGUE, P.C.

   JACOB A. GOLDBERG

   TODD S. COLLINS

   1622 Locust Street

   Philadelphia, PA 19103

   Telephone: 215/875-3000

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   WILLIAM ARNOUVILLE, On Behalf of Himself and

   All Others Similarly Situated,

SNIPPETS:

HYNES & LERACH LLP

San Francisco, CA 94108

Attorneys for Plaintiff

NORTHERN DISTRICT OF CALIFORNIA

NOTICE OF MOTION AND MOTION

THIS COURT SHOULD CONSOLIDATE THE LAWSUITS FOR PURPOSES OF EFFICIENCY

PLEASE TAKE NOTICE that, on May 15, 1998 at 10:00 a.m. in the Courtroom of the Honorable

Court, 1301 Clay Street, Oakland, California 94612, Richard Geffen, Tammy Newman, Louis Luu

The basis for the motion is that these actions are substantially identical, involve the same

Four securities fraud class action lawsuits against the same defendants are presently pending

Wilkes v. Versant Object

Luu v. Versant Object

Because these actions are substantially identical and raise common questions of fact and law,

Each of these cases alleges claims on a class-wide basis on behalf of purchasers of the

Each case alleges that Versant and its senior executive officers disseminated materially

Each of the four actions allege violations of §§10and 20of the Securities Exchange Act of

See Geffen complaint, ¶102; Luu complaint, ¶102; Arnouville complaint, ¶102.

When actions involving a common question of law or fact are pending before the court, it may

THE STATUTE REQUIRES THAT THE QUESTION OF CONSOLIDATION BE DECIDED PRIOR TO THE DETERMINATION

Movants ask the Court to resolve the consolidation motion as soon as practicable and

I declare under penalty of perjury that the foregoing is true and correct.

15 . MEMORANDUM IN SUPPORT OF MOTION TO BE APPOINTED LEAD PLAINTIFFS

EXTRACTED KEY WORDS

LEAD PLAINTIFFS
VERSANT
DEFENDANTS
CO-LEAD COUNSEL
EXCHANGE ACT
MOTION
COURT
GRANT
APPOINTED LEAD PLAINTIFFS
SECURITIES EXCHANGE ACT
APPOINTMENT
SAN FRANCISCO
CLASS MEMBERS
SELECTION
PLAINTIFFS PURSUANT
VERSANT OBJECT
LERACH LLP
MILBERG WEISS
VERSANT STOCK
WILLIAM ARNOUVILLE
UNITED STATES DISTRICT
UNITED STATES
AUTHORITIES
MEMORANDUM
CALIFORNIA
MILBERG WEISS BERSHAD
FEDERAL RULES
VERSANT OBJECT TECHNOLOGY
KATHREIN


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BERGER & MONTAGUE, P.C.

   JACOB A. GOLDBERG

   TODD S. COLLINS

   1622 Locust Street

   Philadelphia, PA 19103

   Telephone: 215/875-3000

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   WILLIAM ARNOUVILLE, On Behalf of Himself and

   All Others Similarly Situated,

SNIPPETS:

- and -REED R. KATHREIN

San Francisco, CA 94108

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND

MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO

§21DOF THE SECURITIES EXCHANGE ACT OF 1934

SELECTION OF CO-LEAD COUNSEL

THE GEFFEN GROUP SHOULD BE APPOINTED AS LEAD PLAINTIFFS

The Geffen Group Has Complied With The PSLRA And Is Entitled To Be Appointed Lead Plaintiffs

Counsel Selected By The Geffen Group Are Qualified, Experienced Class Counsel And Should Be

PLEASE TAKE NOTICE that, on May 15, 1998, at 10:00 a.m. or as soon thereafter as this matter

This motion is based on this notice of motion and memorandum of points and authorities, the

The Wilkes actionwas brought on January 26, 1998 as a class action for securities fraud

Thereafter, three additional complaints were filed in this district on behalf of Geffen,

Wilkes v. Versant Object

Grant Decl., Ex.

The notice advised class members that they had sixty days from January 29, 1998 to bring a

The Geffen Group now requests, pursuant to §21Dof the Exchange Act, that the Court appoint it

The members of the Geffen Group purchased their Versant stock during the Class Period and

The Private Securities Litigation Reform Act establishes a procedure for the appointment of a

The plaintiff in the first action that is filed must publish, within 20 days of filing the

OF MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO §21DOF

The Geffen Group consists of Richard Geffen, Tammy Newman, Louis Luu and William Arnouville

, plaintiffs in the three related actions, together with an additional 40 purchasers of

16 . MEMORANDUM IN OPPOSITION TO MOTION TO DISMISS

EXTRACTED KEY WORDS

VERSANT
PLAINTIFFS
ALLEGATIONS
ALLEGES
MISLEADING
COMPLAINT
MISREPRESENTATIONS
COURT
CIR
PSLRA
MOTION
SUPP
REVENUE
FACTS
PLEADING
CAC
SAN FRANCISCO
LOSS CAUSATION
SECURITIES
ACCOUNTING FRAUD
INDIVIDUAL DEFENDANTS
CALIFORNIA
UNITED STATES
REPRESENTATIONS
CCH
TRANSFER BINDER
PLEAD LOSS CAUSATION
DISTRICT COURT
CO-LEAD COUNSEL


   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   AMBER L. ECK (177882)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
       - and -
   REED R. KATHREIN (139304)
   JOHN K. GRANT (169813)
   100 Pine Street, Suite 2600
   San Francisco, CA 94111
   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE
   STEPHEN R. BASSER (121590)
   ZACHARY BERMAN (178614)
   600 West Broadway, Suite 1700
   San Diego, CA 92101
   Telephone: 619/230-0800

   Co-Lead Counsel for Plaintiffs


                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA





   In re VERSANT OBJECT TECHNOLOGY
   CORP. SECURITIES LITIGATION
   ___________________________________

   This Document Relates To:

                ALL ACTIONS.
   ___________________________________

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SNIPPETS:

San Francisco, CA 94111 Telephone:

Co-Lead Counsel for Plaintiffs

UNITED STATES DISTRICT COURT

In re VERSANT OBJECT TECHNOLOGY

PLAINTIFFS' MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANTS' MOTION TO

SUMMARY OF ALLEGATIONS

THE COMPLAINT IDENTIFIES ACTIONABLE MISREPRESENTATIONS AND ALLEGES WHY THEY WERE FALSE AND

Plaintiffs Adequately Plead Loss Causation

The PSLRA Does Not Mandate Pleading Sources

The Individual Defendants' Access to Internal Information and Responsibility for Critical

F. Supp.

Sec. L. Rep. (CCH) ¶90,108 (C.D.

137 F.3d 616 (9th Cir.

Sec. Litig., (1992 Transfer Binder) Fed.

Yourish v. California Amplifier,

Defendants also caused Versant to report false financial earnings results for 2Q97 and 3Q97

Versant's own favored securities analyst accused defendants of deceiving the market, stating

The CAC specifies which statements plaintiffs challenge and why they were false, alleging in

The CAC also adequately alleges scienter as required by the Ninth Circuit under In re Silicon

Unable to deal with plaintiffs' detailed allegations, identifying specific products,

While defendants would have this Court examine the merits of plaintiffs' allegations, such an

The CAC alleges that Versant reported false financial results for 2Q97 and 3Q97 by using

Defendants' claim that such deception is harmless or that the CAC does not plead loss

Each alleged misstatement is identified by content, date and the document or announcement in

the district court relied on Warshaw to interpret the PSLRA's falsity requirement.

17 . MEMO IN SUPPORT OF MOTION FOR APPOINTMENT OF LEAD PLAINTIFFS

EXTRACTED KEY WORDS

MOVANTS
COURT
CONSOLIDATION
WILKES
SECURITIES
VERSANT OBJECT TECHNOLOGY
MOTION
EXCHANGE ACT
RELATED ACTIONS
ALEXANDER
LEAD COUNSEL
DEFENDANTS
YOURMAN
APPOINTMENT
WEISS
ADEQUATE PLAINTIFF
STEVEN WILKES
VAHN ALEXANDER
CLASS CERTIFICATION
AUTHORITIES
LAWRENCE PULKOWNIK
DAVID BANKS
PURPORTED CLASS
CLASS PERIOD
REPRESENTING
FEDERAL RULES
APPOINTED LEAD PLAINTIFF
MEMORANDUM
UNITED STATES DISTRICT


   Kevin J. Yourman (CSB #147159)
   Vahn Alexander (CSB #167373)
   WEISS & YOURMAN
   10940 Wilshire Boulevard
   24th Floor
   Los Angeles, CA 90024
   (310) 208-2800

   Attorneys for Plaintiffs/Movants

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   STEVEN WILKES, On Behalf of Himself And All
   Others Similarly Situated,

                         Plaintiff,

              v.

   VERSANT OBJECT TECHNOLOGY, INC.,
   DAVID BANKS, JAMES R. LOCHRY,
   LAWRENCE PULKOWNIK, GEORGE C.
   FRANZEN, RONALD KOPECK, GARY RHEA,
   and LAWRENCE K. ORR,

                         Defendants.
   _________________________________________

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SNIPPETS:

WEISS & YOURMAN

UNITED STATES DISTRICT COURT

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOVANTS' MOTION FOR APPOINTMENT OF LEAD

Plaintiff Steven Wilkes Filed The First Complaint In This Action

THIS COURT SHOULD APPROVE MOVANTS' CHOICE OF LEAD

SECTION 21D OF THE EXCHANGE ACT REQUIRES THAT CONSOLIDATION BE DECIDED PRIOR TO THE

Federal Rules of Civil Procedure 42

Plaintiff Steven Wilkes, along with other class members,1 respectfully submit this memorandum

Section 21D provides, in relevant part, that within 60 days after publication of a notice

Having filed the instant motion within the 60-day period prescribed by §21D, Movants now

This case concerns a securities class action filed on behalf of all persons or entities who

The Complaint alleges that defendants participated in a scheme or common course of conduct to

a "member or members" of the class or a "person or group of persons" may combine to

Jan. 13, 1997) (See Alexander Decl., Exhibit C).6

Moreover, of the four prerequisites of class certification under Rule 23, only two --

is subject to unique defenses that render such plaintiff incapable of adequately representing

The attorneys at Weiss & Yourman with primary responsibility for prosecuting this action are

Defendants include Versant, David Banks, James R. Lochry, Lawrence Pulkownik, George C.

22 . DECLARATION OF VAHN ALEXANDER IN SUPPORT OF MOTION FOR APPOINTMENT

EXTRACTED KEY WORDS

EXHIBIT
COUNSEL
APPOINTMENT
MOTION
SLIP
ORDER GRANTING
DECLARATION
CALIFORNIA
VAHN ALEXANDER
YOURMAN
WEISS
CIV
LITIG
FIRM
LAW
MOVANTS
SUPPORT
LAWRENCE
VERSANT OBJECT TECHNOLOGY
COURT
DISTRICT
ATTORNEYS
LOS ANGELES
CSB
POWERS
ARIZ
PHX RCB
CHAN
TEX


   Kevin J. Yourman (CSB #147159)
   Vahn Alexander (CSB #167373)
   WEISS & YOURMAN
   10940 Wilshire Boulevard
   24th Floor
   Los Angeles, CA 90024
   (310) 208-2800

   Attorneys for Plaintiffs/Movants

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   STEVEN WILKES, On Behalf of Himself And All
   Others Similarly Situated,

                         Plaintiff,

              v.

   VERSANT OBJECT TECHNOLOGY, INC.,
   DAVID BANKS, JAMES R. LOCHRY,
   LAWRENCE PULKOWNIK, GEORGE C.
   FRANZEN, RONALD KOPECK, GARY RHEA,
   and LAWRENCE K. ORR,

                         Defendants.
   _________________________________________

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   )
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SNIPPETS:

Vahn Alexander (CSB #167373)

WEISS & YOURMAN

Attorneys for Plaintiffs/Movants

NORTHERN DISTRICT OF CALIFORNIA

and LAWRENCE K. ORR,

DECLARATION OF VAHN ALEXANDER IN SUPPORT OF MOVANTS' MOTION FOR APPOINTMENT OF LEAD

I, Vahn Alexander, declare:

I am an attorney at law duly licensed to practice in the State of California and before this

I am associated with the firm of Weiss & Yourman, counsel of record for plaintiffs/movants in

Chart of Versant Object Technology Plaintiff Transactions.

Exhibit B: The notice of pendency of this action as published on Business Wire on January 29,

Sec. Litig., No. C-97-20059-RMW, slip op.

May 23, 1997), Order Granting Plaintiffs' Motion For Appointment of Lead Plaintiff and Lead

Tex.

Chan v. Orthologic Corp., No. Civ.

96-1514 PHX RCB, slip op.

Ariz.

Exhibit H: Powers v. Eichen,

Executed this 28th day of March, 1998 at Los Angeles, California.

23 . DECLARATION OF JOHN K GRANT IN SUPPORT OF MOTION 2

EXTRACTED KEY WORDS

LEAD PLAINTIFFS
SAN FRANCISCO
MOTION
CALIFORNIA
EXHIBIT
APPOINTMENT
SUPPORT
UNITED STATES
GRANT
JOHN
CO-LEAD COUNSEL
LEAD PLAINTIFFS PURSUANT
VERSANT OBJECT TECHNOLOGY
LERACH LLP
FIRM RéSUM
LAW
SELECTION
EXCHANGE ACT
SECURITIES EXCHANGE ACT
NORTHERN DISTRICT
WEISS BERSHAD HYNES
MILBERG WEISS BERSHAD
THERETO
TESTIFY
WITNESS
PRACTICE
AUTHORITIES
MEMORANDUM
COURT

   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE

   STEPHEN R. BASSER (121590)

   BLAIR A. NICHOLAS (178428)

   600 West Broadway, Suite 1700

   San Diego, CA 92101

   Telephone: 619/230-0800

   BERNSTEIN LIEBHARD & LIFSHITZ

   MEL E. LIFSHITZ

   274 Madison Avenue

   New York, NY 10016

   Telephone: 212/779-1414

SNIPPETS:

JOHN K. GRANT

UNITED STATES DISTRICT COURT

GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND MEMORANDUM OF

POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO BE

OF LEAD PLAINTIFFS' SELECTION OF CO-LEAD COUNSEL

I am an attorney duly licensed to practice law in the State of California and am admitted to

I am associated with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, one of the

I make this declaration in support of Geffen Group's motion to be appointed lead plaintiffs

I have personal knowledge of the facts set forth below and if called as a witness could and

Exhibit 1: Sworn Certifications of the Geffen Group;

Firm Résumé of Milberg Weiss Bershad Hynes & Lerach LLP;

Executed this 30th day of March, 1998, at San Francisco, California.

PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2

That on March 30, 1998, declarant served the DECLARATION OF JOHN K. GRANT IN SUPPORT OF

24 . DECLARATION OF JOHN K GRANT IN SUPPORT OF MOTION

EXTRACTED KEY WORDS

LEAD PLAINTIFFS
SAN FRANCISCO
MOTION
CALIFORNIA
EXHIBIT
APPOINTMENT
SUPPORT
UNITED STATES
CO-LEAD COUNSEL
GRANT
JOHN
LEAD PLAINTIFFS PURSUANT
VERSANT OBJECT TECHNOLOGY
LERACH LLP
FIRM RéSUM
LAW
SELECTION
EXCHANGE ACT
SECURITIES EXCHANGE ACT
NORTHERN DISTRICT
WEISS BERSHAD HYNES
MILBERG WEISS BERSHAD
PERJURY
PENALTY
THERETO
TESTIFY
WITNESS
PRACTICE
AUTHORITIES


   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE

   STEPHEN R. BASSER (121590)

   600 West Broadway, Suite 1700

   San Diego, CA 92101

   Telephone: 619/230-0800

   (Proposed) Co-Lead Counsel for Plaintiffs

   and Attorneys for Plaintiffs in

   Geffen, No. C-98-0440-MMC;

   Luu, No. C-98-0969-SBA;

   Arnouville, No. C-98-1079-FMS

                        UNITED STATES DISTRICT COURT

SNIPPETS:

JOHN K. GRANT

UNITED STATES DISTRICT COURT

GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND MEMORANDUM OF

POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO BE

OF LEAD PLAINTIFFS' SELECTION OF CO-LEAD COUNSEL

I am an attorney duly licensed to practice law in the State of California and am admitted to

I am associated with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, one of the

I make this declaration in support of Geffen Group's motion to be appointed lead plaintiffs

I have personal knowledge of the facts set forth below and if called as a witness could and

Exhibit 1: Sworn Certifications of the Geffen Group;

Firm Résumé of Milberg Weiss Bershad Hynes & Lerach LLP;

I declare under penalty of perjury under the laws of the State of California that the

Executed this 30th day of March, 1998, at San Francisco, California.

PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2

That on March 30, 1998, declarant served the DECLARATION OF JOHN K. GRANT IN SUPPORT OF

25 . DECLARATION OF JOHN K GRANT IN SUPPORT OF MEMORANDUM

EXTRACTED KEY WORDS

LEAD PLAINTIFFS
MOTION
CALIFORNIA
SAN FRANCISCO
EXHIBIT
APPOINTMENT
SUPPORT
UNITED STATES
GRANT
JOHN
CO-LEAD COUNSEL
LEAD PLAINTIFFS PURSUANT
VERSANT OBJECT TECHNOLOGY
LERACH LLP
FIRM RéSUM
LAW
SELECTION
EXCHANGE ACT
SECURITIES EXCHANGE ACT
NORTHERN DISTRICT
WEISS BERSHAD HYNES
MILBERG WEISS BERSHAD
FOREGOING
PERJURY
PENALTY
THERETO
TESTIFY
WITNESS
PRACTICE

   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   COHEN, MILSTEIN, HAUSFELD

   & TOLL, P.L.L.C.

   STEVEN J. TOLL

   KRISTOPHER A. KINCADE

   999 Third Avenue, Suite 3600

   Seattle, WA 98104

   Telephone: 206/521-0080

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

                              OAKLAND DIVISION

SNIPPETS:

JOHN K. GRANT

UNITED STATES DISTRICT COURT

GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND MEMORANDUM OF

POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO BE

OF LEAD PLAINTIFFS' SELECTION OF CO-LEAD COUNSEL

I am an attorney duly licensed to practice law in the State of California and am admitted to

I am associated with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, one of the

I make this declaration in support of Geffen Group's motion to be appointed lead plaintiffs

I have personal knowledge of the facts set forth below and if called as a witness could and

Exhibit 1: Sworn Certifications of the Geffen Group;

Firm Résumé of Milberg Weiss Bershad Hynes & Lerach LLP;

I declare under penalty of perjury under the laws of the State of California that the

Executed this 30th day of March, 1998, at San Francisco, California.

PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2

26 . DECLARATION OF JOHN K GRANT IN OPPOSITION TO MOTION TO DISMISS 2

EXTRACTED KEY WORDS

SAN FRANCISCO
CALIFORNIA
UNITED STATES
GRANT
JOHN
PLAINTIFFS
DISMISS
MOTION
DEFENDANTS
MEMORANDUM
NORTHERN DISTRICT
LERACH LLP
THEREOF
FOREGOING
PERJURY
PENALTY
LAW
OPPOSITION
AUTHORITIES
SUPPORT
COURT
COUNSEL
SAN DIEGO
HYNES
MILBERG WEISS BERSHAD
THEREON FULLY PREPAID
SEALED ENVELOPE
UNITED STATES MAILBOX
DEPOSITING


   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   AMBER L. ECK (177882)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
       - and -
   REED R. KATHREIN (139304)
   JOHN K. GRANT (169813)
   100 Pine Street, Suite 2600
   San Francisco, CA 94111
   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE
   STEPHEN R. BASSER (121590)
   600 West Broadway, Suite 1700
   San Diego, CA 92101
   Telephone: 619/230-0800

   Co-Lead Counsel for Plaintiffs


                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA





   In re VERSANT OBJECT TECHNOLOGY
   CORP. SECURITIES LITIGATION
   ___________________________________

   This Document Relates To:

                ALL ACTIONS.
   ___________________________________

   )
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   )
   )

SNIPPETS:

San Diego, CA 92101 Telephone:

UNITED STATES DISTRICT COURT

DECLARATION OF JOHN K. GRANT IN SUPPORT OF PLAINTIFFS' MEMORANDUM OF POINTS AND AUTHORITIES

I am an attorney duly licensed to practice before all of the courts of the State of

I am an associate at the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, one of the

I declare under penalty of perjury under the laws of the State of California that the

Executed this 14th day of February, 2000, at San Francisco, California.

PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2

IN OPPOSITION TO DEFENDANTS' MOTION TO DISMISS by depositing a true copy thereof in a United

27 . DECLARATION OF JOHN K GRANT

EXTRACTED KEY WORDS

LEAD PLAINTIFFS
MOTION
CALIFORNIA
SAN FRANCISCO
EXHIBIT
APPOINTMENT
SUPPORT
UNITED STATES
GRANT
JOHN
CO-LEAD COUNSEL
LEAD PLAINTIFFS PURSUANT
VERSANT OBJECT TECHNOLOGY
LERACH LLP
FIRM RéSUM
LAW
SELECTION
EXCHANGE ACT
SECURITIES EXCHANGE ACT
NORTHERN DISTRICT
WEISS BERSHAD HYNES
MILBERG WEISS BERSHAD
FOREGOING
PERJURY
PENALTY
THERETO
TESTIFY
WITNESS
PRACTICE

   MILBERG WEISS BERSHAD

   HYNES & LERACH LLP

   WILLIAM S. LERACH (68581)

   AMBER L. ECK (177882)

   600 West Broadway, Suite 1800

   San Diego, CA 92101

   Telephone: 619/231-1058

   - and -

   REED R. KATHREIN (139304)

   JOHN K. GRANT (169813)

   222 Kearny Street, 10th Floor

   San Francisco, CA 94108

   Telephone: 415/288-4545

   BERGER & MONTAGUE, P.C.

   JACOB A. GOLDBERG

   TODD S. COLLINS

   1622 Locust Street

   Philadelphia, PA 19103

   Telephone: 215/875-3000

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   WILLIAM ARNOUVILLE, On Behalf of Himself and

   All Others Similarly Situated,

SNIPPETS:

JOHN K. GRANT

UNITED STATES DISTRICT COURT

GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND MEMORANDUM OF

POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO BE

OF LEAD PLAINTIFFS' SELECTION OF CO-LEAD COUNSEL

I am an attorney duly licensed to practice law in the State of California and am admitted to

I am associated with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, one of the

I make this declaration in support of Geffen Group's motion to be appointed lead plaintiffs

I have personal knowledge of the facts set forth below and if called as a witness could and

Exhibit 1: Sworn Certifications of the Geffen Group;

Firm Résumé of Milberg Weiss Bershad Hynes & Lerach LLP;

I declare under penalty of perjury under the laws of the State of California that the

Executed this 30th day of March, 1998, at San Francisco, California.

PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2

28 . CONSOLIDATED AMENDE COMPLAINT

EXTRACTED KEY WORDS

VERSANT OBJECT TECHNOLOGY
STOCK
DEFENDANTS
DEMAND
BUSINESS
REVENUE
COMMON STOCK
SECURITIES
MANAGEMENT
CUSTOMER
ACT
REPORTS
OBJECT DATABASE
MARKET
SALES
APPLICATIONS
CLASS PERIOD
TIMES MATERIAL HERETO
MISLEADING
VERSANT ODBMS
DISTRIBUTION
VICE PRESIDENT
CALIFORNIA
EXPERIENCING
EPS
CUSTOM SPEC
NETWORK COMPUTING
ENTERPRISE
PARTNER PROGRAM


   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   AMBER L. ECK (177882)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
        - and -
   REED R. KATHREIN (139304)
   JOHN K. GRANT (169813)
   222 Kearny Street, 10th Floor
   San Francisco, CA 94108
   Telephone: 415/288-4545

   BARRACK, RODOS & BACINE
   STEPHEN R. BASSER (121590)
   BLAIR A. NICHOLAS (178428)
   600 West Broadway, Suite 1700
   San Diego, CA 92101
   Telephone: 619/230-0800

   Co-Lead Counsel for Plaintiffs

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

   In re VERSANT OBJECT TECHNOLOGY
   CORP. SECURITIES LITIGATION
   __________________________________
   This Document Relates To:
   ALL ACTIONS.
   ____________________________________

   )
   )
   )
   )
   )
   )
   )
   )
   )
   )
   )
   )
   )

SNIPPETS:

In re VERSANT OBJECT TECHNOLOGY

CONSOLIDATED AMENDED CLASS ACTION COMPLAINT FOR VIOLATION OF THE SECURITIES EXCHANGE ACT OF

This action arises out of defendants' fraudulent scheme and common course of conduct to

Versant designs and markets computer software for high-performance enterprise component

Incorporated in August 1988, Versant began shipment of its principal product, the Versant

During 1Q97, Versant stock was a poor performer, declining significantly amid inves