UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CAMILLE DEFILLIPPO, on behalf of herself
and all others similarly situated, Civ. No.
Plaintiff, CLASS ACTION COMPLAINT
v.
JURY TRIAL DEMANDED
WORLDWIDE XCEED GROUP, INC.,
SCOTT A. MEDNICK, WERNER G.
HAASE, NURIT K. HAASE, WILLIAM
ZABIT, and JOHN P. GANDOLFO,
Defendants
Plaintiff, for her class action complaint, alleges upon personal knowledge as to herself
and her own acts, and upon information and belief as to all other matters, based upon the
investigation made by and through her attorneys, which included, inter alia, a review of articles
in the financial news media, press releases, and other publicly available information concerning
trading in the securities of Worldwide Xceed Group, Inc., formerly named Xceed, Inc.
NATURE OF THE ACTION
1. This is a class action on behalf of a class (the "Class") of all persons who
purchased the common stock of Worldwide Xceed Group, Inc., formerly named Xceed, Inc.
(hereinafter "Xceed" or the "Company"), between November 29, 1999, and November 15,
2000 (the "Class Period), seeking to pursue remedies under the Securities Exchange Act of
1934.
JURISDICTION AND VENUE
2. This action arises under §10(b)of the Securities & Exchange Act of 1934
(the "Exchange Act") and Rule 10b-5 promulgated thereunder by the SEC, 17 C.F.R.
§240.10b-5.
3. Jurisdiction is conferred upon this Court by §27 of the Exchange Act, 15
SNIPPETS:
WORLDWIDE XCEED GROUP, INC., SCOTT A. MEDNICK, WERNER G. HAASE, NURIT K. HAASE, WILLIAM
investigation made by and through her attorneys, which included, inter alia, a review of
trading in the securities of Worldwide Xceed Group, Inc., formerly named Xceed, Inc.
This action arises under §10of the Securities & Exchange Act of 1934
In connection with the acts alleged herein, defendants, directly or indirectly,
Plaintiff Camille Defillippo purchased Xceed common stock during the Class
Defendant Scott A. Mednick was, at all relevant times, Co-Chairman of the Board of Directors
Defendant William Zabit was, at all relevant times up to March 2000,
The members of the Class are located throughout the United States.
Class and has retained counsel competent and experienced in class action securities
Identifiable Intangible Assets stating, in pertinent part, as follows:
Goodwill and other intangible assets resulting from the Company's acquisitions of Internet
The First Quarter 10-Q reported that Xceed had revenues of $18,207,000 and a net
This statement establishes financial accounting and reporting standards for the impairment of
The Company reviews long-lived assets and certain identifiable intangibles to be held and
Additionally, in the 1999 Amended 10-K, Xceed set forth its accounting policy
The net losses reported in the First Quarter 10-Q and the Second Quarter 10Q were materially
The understatement of the net losses resulted from, among other things, a
a company's financial statements are required to state
increased the provision for the allowance of uncollectible accounts receivable in the amount
did Xceed's allowance for uncollected accounts receivables suddenly increase to $9,350,000,
representation that the amortization would occur over seven years,
Revenues for the Company's Internet Professional Services and Performance Enhancement
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