PLEASE
FILE
STAMP
AND
REMRlj
UNITED STATES DISTRICT OURT
MIDDLE DIS'SRICT OF FLORIDA
Plainrift
V.
KENNETH R. VKNES; HQWtLRD "SKIP"'
SPEAKS; BRAZN J. ANDREW; JOSBPR
ANT'INLJCCI; STANELY R. ART,KJR;
BANDEL L. CARANO; JAM33 F. GIBBONS;
ROBERT P. GOODhb4N; #RI-UN GUPTA;
JAMES WEI; CREDIT SUISSE FIRS?:
BOSTON CORPORATION; DEUTSCHE
BANC ALEX BROWN; U.S. BANCORF
PlpER JAFFRAY MC.; ERNST & YOUNG,
LLP; U.S. TELESOURCE, INC.; and OAK
INVESTMENT PARTNERS,
Defendants.
CLASS ACTIQN COl'kfPLM'NT
Plaintiffmakes the following allegations, except as to allegations specifically
plaintiff, upon the investigation of plaintiff6 counsel, whi& inveutigation included analysis of
publicly-available news articles and repo:rts, public flings, press releases and other matters
record, and consultation with a forensic accountant.
NATURE OF TBE ACTIO&
3. This is a class action on behalf of all purchasers of the common stock of T&on
Network Systems, Inc. ("Triton" or the "Company") between July 13,200O and August 14,200l
SNIPPETS:
BOSTON CORPORATION; DEUTSCHE BANC ALEX BROWN; U.S. BANCORF
PlpER JAFFRAY MC.; ERNST & YOUNG, LLP; U.S. TELESOURCE, INC.; and OAK
This is a class action on behalf of all purchasers of the common stock of T&on
Network Systems, Inc. between July 13,200O and August 14,200l
Ykmities Act") and the Securities Exchange Act of 1934.
This action arises under Sections 1 I, and 15 of the Securities Act (1.5 U.S.C. 5 77k
District and Triton maintained its principal execuLive offices in this District.
In connection with the acts al>d omissions alleged in this complaint, defendants,
Plaintiff purchased Triton common stock during the Class Period,
as senior officers and/or directors of Tri?on signed the
Registration Statement which included the materially false wd misleading
Defend.ant Credit Suisse Pirst Boston acted as the lead underwriter of the July 13,
2000 initial p'ublic offering ofTriton common stock.
U.S. Telesource, Inc., a, wholly-owned.
Oak Investment Partners is a ventu,re capital fi and a shareholder in Triton.
Excluded from the Class are defendants, members of the immediate family of each of the
There will be no difficulty in the management Of this suit as a class aotion.
The prospectus for the JuIy l3,2000 offering states that the Company was founded
The Prospectus elaborated on the magnitude of the supply agreement with ART as
The foregoing representations were false and misleading,
representations regarding ART's firm commitment to purchase and,pay for the above quantities.
directors and related parties, particularly U.S. Telesource and Oak, are able
"James Wei has served on our board of directors since November 1997.
Agafast Defendants Vines, Speaks, Andrew, Antl~nuccf, Arthur, Caraao, Gfbbons, Goodman, @upa:
Plaintiff repeats and realleges each and every allegation contained in the above
of the Prospectus and caused its filing with the SEC, Defendants Vines, Speaks, Andrew,
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