UNlITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
FRWK DENTON, Individually And On Behalf of )
ALI Others Simiiarly Situated, _- ) CIVIL ACTION NO.
)
Plaintiff, 1
1
vs. ) CLASS ACTION
) FOR VIOLATIONS
FLEXTRONICS INTERNATIONAL, LTD, ) FEDERAL SECURITIES LAWS
MICHAEL E. MARKS, MICHAEL MCNAMARA 3
and ROBERT R B. DYKES, 1
) JURY TRIAL DEMANDED
Defendants. ' 1
>
Plaintiff has alleged the following based upon the investigation of plaintiffs
which included a review of United States Securities and Exchange Commission ("SEC") filings by
Flextronics International, Ltd. ("Flextronics" or the "Company"), as well as reguiarorq
.
repons, securities analysts' reports and advisories abow tie Company, press releases and other
statements issued by the Company, and media reports about rhe Company, and pIaintif?`believes that
substantial additional evidentiary support will exist for the allegations set forth herein
reasonable opportunity for discovery.
NATURE OF TRE ACTION
1. This is a federal class action on behalf of purchasers of the common stock
Flextronics benveen October 2, 2001 and June 4, 2002 inclusive (the "Class Period"), seeking to
pursue remedies under the Securities Exchange Act of 1934 (the "Exchange Act").
: `.; .
, -* : 5 . `,.L . .
JURISDICTION AND VENUE
3
m. The claims asserted herein arise under and pursuant to Sections IO(b)
SNIPPETS:
Plaintiff has alleged the following based upon the investigation of plaintiffs counsel,
Flextronics International, Ltd., as well as reguiarorq filings and
repons, securities analysts' reports and advisories abow tie Company, press releases and
pursue remedies under the Securities Exchange Act of 1934.
its principal place of business located within,
has substantial manufacturing facilities within the United States and conducts substantiaI
purchased the common stock of Flextronics at artificially inflated prices during
Flextronics provides electronics manufacturing
allegations raised herein was, President of American Operations of Flextronics.
It is appropriate to treat the Individual Defendants as a group for pleadie purposes
by virtue of their high-level positions with the Company, directly participated in the
National Market, and governed by the provisions of the federal securities laws, the
and to correct any previously-issued statements that had become materially misleading
Flextronics and its business issued or adopted by the Company materially false and misleading.
Each Individuai Defendant was provided with copies of the documents alleged herein to be
business that operated as a fraud or deceit on purchasers of Flextronics common stock by
disseminating materially false and misleadiig statements and/or concealing material adverse
members of the Class to purchase Flextronics securities at arcificiatly inflated prices.
Plaintiff brings this action as,a class action pursuant to Federal Rule of Civil
Period misrepresented material facts about the business,
provided to analysts and investors.
restructuring, As defendant Marks then stated, "all these restructuring charges are
annual analysts' conference in New York City, during which the CEO, defendant Marks, announced
"The Company has achieved its growth in this difficult market environment through the
shareholders, signed by defendant Marks, in which defendants continued to downplay the impact
the material misrepresentations and omissions particularized
the issuance or dissemination of such statements or documents as primary violations of the
and continued substantial growth, which included the making of, or the participation in the
|
