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1
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS CLASS ACTION OFFICER ACT REVENUE REPORTS OFTHE NETWORK STOCK SUBSTANTIAI PRICE INDIVIDUAL DEFENDANTS CASH REVENUE PERFORMANCE CAPITAL CORPORATION SECURITIES ANALYSTS MISLEADING BUSINESS PLAN PLAINTIFFS SOUTH AMERICA MATERIAL FACTS CUSTOMERS PURPORTED RECORD BREAKING PERTINENT REGULATORY FILINGS REASONABLE OPPORTUNITY PURCHASERS VIOLATIONS INVESTORS EXPERIENCING GROWTH DESPITE |
PERFORMANCE CAPITAL CORPORATION and j
RAN'VILLE LUCK, On Behalf of Themselves and j CML ACTION EO.
On Behalf ofAll Others Similarly Situated,
;
Plaintiffs, )
) CLASS ACTION COMPLAINT
+S. ) FOR VIOLATIONS OF
> FEDERAL SECWES LAWS
GREGORY B. KQ?FEI, JIMIXY D. BYl?D, B
LARRY OLSEN, RON STEVENSON, VMSSA )
WITTMAJ? and STEVE BAKEB, )
)
Defendants.
by %ONetworks, Inc. ("36ONetworlcs" or the `lCompan~), as well as regulatory filings and
reports, securities analysts' reports and advisories about the Company, press releases and 0th~
*
public statements issued by the Company, and media reports about the Company, and plaintif%
believe that substantial additiona evidentiq support will exist for the allegations set forth
herein after a reasonable opportunity for discovery.
1. This is a securities class action on behalf of all purchasers of the publicly
securities of360Networks between November 2$2000 and Jupe 28,ZOOl (the "Class Period"),
against 36ONetworks ai$%&$q&++f,its officers and'hirectors for violations of the Securities
6.? ." ,,_ - -"(?!Q
Exchange Act of 1934 (de'"1934 A@`>.,.. ? . "
JUFUSDICTION AND VENUE
?
d. Jurisdiction is conferred by $27 ofthe 1934 Act. The claims asserted
under $5 1 O(b j and 20(a) of the 1934 Act and Rule 106-5.
3. Venue is proper in this District pursuant to $27 of the 1934 Get. Many
fake and misleading statements were made in or issued from this District.
SNIPPETS:
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