UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
SHAWN KOEHN, on Behalf of Himself and all
Others Similarly Situated,
>
Plaintiff, >
) CLASS ACTION CiZiiiJPLAjtiT
vs. ) FOR VIOLATIONSh~
) FEDERAL SECURI&S-LA@*?
PERKINELMER, INC., GREGORY L. SUMME )
and ROBERT F. FRIEL, >
) JURY TRIAL .,,,,;&
Defendants.
>
Plaintiff has alleged the following based upon the investigation of plaintiffs
which included a review of United States Securities and Exchange Commission ("SEC")
by PerkinElmer, Inc. ("PerkinElmer" or the "Company"), as well as regulatory filings and
securities analysts reports and advisories about the Company, press releases and other
statements issued by the Company, and media reports about the Company, and plaintiff
that substantial additional evidentiary support will exist for the allegations set forth
reasonable opportunity for discovery.
NATURE OF THE ACTION
1. This is a federal class action on behalf of purchasers of the securities
PerkinElmer between July 15,200l to April 11,2002, inclusive (the "Class Period"),
pursue remedies under the Securities Exchange Act of 1934 (the "Exchange Act").
JURISDICTION AND VENUE
2. The claims asserted herein arise under and pursuant to Sections 1 O(b)
SNIPPETS:
Plaintiff has alleged the following based upon the investigation of plaintiffs counsel,
by PerkinElmer, Inc., as well as regulatory filings and reports,
securities analysts reports and advisories about the Company,
reasonable opportunity for discovery.
pursue remedies under the Securities Exchange Act of 1934.
Many of the acts charged herein, including the preparation and dissemination of materially
defendants maintain their chief executive offices and principal place of business
purchased the common stock of PerkinElmer during the Class
PerkinElmer is a diversified technology company, operating in three segments: Life Sciences,
The Individual Defendants also had access to material adverse non-public information
presentations to securities analysts and through them,
directors of the Company, at all relevant times, members of their immediate families and
Class and has retained counsel competent and experienced in class and securities litigation.
Life Sciences, Analytical Instruments and Optoelectronics.
their statements concerning the Company's prospects, earnings and value.
.the Company.could.use its common stock as currency for a major corporate acquisition.
strategic importance and benefits of the acquisition, defendant Summe stated that Packard's
PerkinElmer common stock for each share of Packard Bioscience common stock."
`Aggressive actions starting earlier in the year are allowing us to deliver our financial
representatives at the conference to the market.
following day, December 6, 2002, defendant Friel sold 150,000 common shares at $33.10 per
PerkinElmer common stock traded at artificially inflated prices during the
the material misrepresentations and omissions particularized
purchasers of PerkinElmer's securities during the Class Period suffered similar injury through
Plaintiff repeats and realleges each and every allegation contained above as if fully
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