UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
____________________________________) Civil Action
IN RE CLARUS CORPORATION ) No. l:00-CV-2841-CAP
)
SECURITIES LITIGATION )
____________________________________)
PLAINTIFFS* AMENDED CONSOLIDATED CLASS ACTION COMPLAINT
Plaintiffs John Nittolo, Dean Monroe, Ronald Williams, V&S Industries Ltd.,1 VIP World
Asset Management Ltd., Atlantic Coast Capital Management Ltd., T.F.M. Investment Group, and
William Dell ("Plaintiffs"), by and through their attorneys, allege the following upon personal
as to those allegations concerning themselves and, as to all other matters, upon investigation of
which included: (a) review and analysis of public filings made by Clarus Corporation ("Clarus" or
"Company"), with the Securities and Exchange Commission (the "SEC"); (b) review and analysis of
securities analysts* reports concerning Clarus; (c) review and analysis of Clarus press releases,
available information, other public statements made by or on behalf of Clarus and/or any of the
defendants; (d) contact with factual sources, including interviews with individuals who were
employed by Clarus during the Class Period; (e) online research, including a review of Clarus*s
website; (f) reference to authoritative accounting literature; and (g) consultation with forensic
experts.
1 V&S Industries Ltd., VIP World Asset Management Ltd., and Atlantic Coast Capital
Management Ltd. are all corporate entities beneficially owned by Scott E. Schalk and Victor DeFrisco
1
2 237518
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PLAINTIFFS* AMENDED CONSOLIDATED CLASS ACTION COMPLAINT
review and analysis of public filings made by Clarus Corporation ("Clarus" or the
securities analysts* reports concerning Clarus; review and analysis of Clarus press releases,
employed by Clarus during the Class Period; online research,
This is a class action under the Securities Exchange Act of 1934
Clarus Corporation between December 8, 1999 and October 25, 2000 (the "Class
and who suffered damages as a result of defendants* concerted fraud (the
defendants represented to be available to customers in December 1999.
business-to-business e-commerce industry.
nearly as strong as the Company*s Class Period representations indicated.
The price of Clarus common stock plummeted, from nearly $20 per share to $11 1/16
Clarus recognized the revenue from this customer in 1999, and even though this account was
dissemination to the investing public of false and misleading information,
Investment Group purchased Clarus common stock during the Class Period and, in the aggregate,
Clarus purports to develop, market and support
The sourcing aspect of Clarus*s business, among other things, provides
reports and other information provided to them in connection therewith.
Period omitted and/or misrepresented material facts, and whether defendants breached any duty
ATLANTA - - - - Dec. 8, 1999 - Deloitte & Touche, Clarus Team to Deliver Clarus Fusion Links
, a leading business-to-business ecommerce solution provider, announced today the delivery of
Clarus Fusion*s seamless integration process drastically reduces implementation times and
- Total Cost of Ownership - Rather than requiring a costly custom integration effort, Clarus
Wall Street*s fourth quarter 1999 expectations.
Defendant Jeffery commented on the Company*s seemingly stellar growth,
Clarus, instead, faced stiff competition.
Clarus Fusion is an XML-based integration framework that enables customers to quickly and
revenue in the fourth quarter and receivables in the fourth and first quarter,
And Concentrations Of Credit Risk) which states:
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