UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.
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ERNEST PEDATE, Mividually and. on b&al~f
all others similarly situated,
Plaintiff,
personal knowled.ge as to himself and his own acts, and upon information and belief based upon the
investigalion of Plaintiffs attorneys as to all other matters, The investigation includes the
review and analysis ofpublic sta,tem.ents,
publicly-filed documents of AppliedDigital Sohrtions,
("Applied Digital" or the "Company"), press releases, news articles and the retiew and analysis of
accounting rules and related literature. Pltitiff'believes that further substantial evidentiary
will exist for rhe allegations set forth below after a reasonable opportunity for discovery.
S~RU OF ACTIOW
1. This i,s a securities class a.ction on behalf of pub1i.c investors who purchased
common stock of Applied, Digital dwing the period from Febmary 1.1,2000, throu,gh May 10,2002
(the. "Cl.ass Period"). Plaintiff complains of a fraudulent scheme and deceptive course of
that injured purchasers of Applied Di,gital. stock d,uring the Class Period.
1
2. Applied Digital is a Missouri corporation with its principal place ofbusiness in
Beach, Florida. Applied. Digital develops and markets business-to-business electronic comrnerc
products and'senrices and implantable identification systems,
3. Applied Digital is listed on the!
NASDAQ National Market and as of Marc826,206:
SNIPPETS:
accounting rules and related literature.
Pltitiff'believes that further substantial evidentiary support
will exist for rhe allegations set forth below after a reasonable opportunity for discovery.
This i,s a securities class a.ction on behalf of pub1i.c investors who purchased the
Plaintiff complains of a fraudulent scheme and deceptive course of business
stock d,uring the Class Period.
On Februaq 11,2000, the first day of the class period, defendants were in possessio:
of materially adverse information concerning the lack of proper accounting controls and
.revenue recognition practices at certain of its subsidiaries, After they became aware of
accounting practices at its subsid.iaries, def&ants failed to disclose the information to
every major hospi&l in the West Palm Beach; Florida, area would be equipped with VeriChi
false and misleading statements concem.ing the accounting practices at one of Applied Di&tal',
rind misl.eadi.ng statements concerning Appl,ied Digital's VeriChip technology.
Exchange Act of 1934, 28 USC $5 1331 and 1337.
Plaintiff purchased shares of Applied Digital common stock during the Class Period
Sullivan commu,nicated with members of the Audit Commiftee and, PWC.
Applied Digital is B Missouri corporation with its principal place ofbusiness in Palm
After they became aware of improper accounting practices at its
Digital Aunounces Preliminary 1999 Year-end Revenue Results for Its Core Business Group."
Applied Digital Solutions, ITIC,.
million from $55.6 million, EBITDA increased l,OOO% to $16.5
dissemination of such statements or documents.
Plnintiff repeats and realleges each ar,d every allegation contained in the foregoing
The Individual Defendant is liable as a direct participant in and as controlling person of
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