MILBERG WEISS BERSHAD
HYNES & LERACH LLP
WILLIAM S. LERACH (68581
DARREN J. ROBBINS (16859 4 )
401 B Street, Suite 1700
San Diego, CA 92101
Tele hone: 619/231-1058
619&31-7423 (fax)
SCHIFFRIN & BARROWAY, LLP -
. .
MARC A. TOPAZ
f
Three Bala Plaza East, Suite 400 .:-
Bala Cynwyd, PA 19004
7
Tele hone: 6 1 O/667-7706
6 1 OA67-7056 (fax)
E
g CAULEY, GELLER, BOWMAN
& COATES, LLP
1c PAUL J. GELLER
One Boca Place, Suite 421A
11 2255 Glades Road
Boca Raton, FL 3343 1
12 Tele hone: 56 l/750-3000
56 l/%0-3364 (fax)
13 Attorneys for Plaintiff
14
15 UNITED STATES DISTRICT COURT
16 CENTRAL DI!STRICT OF CALIFORNIA
17 SOUTHERN DIVISION
18 YVETTE VEIDEMAN, On Beha&& C )-&X2-7 12 GLT (AN x)
19 Herself and All Others Similarly .
Situated, CLASS ACTION
20
Plaintiff, COMPLAINT FOR VIOLATION
21 THE SECURITIES EXCHANGE
vs. ACT OF 1934
22
[CN PHARMACEUTICALS, INC.,
23 MILAN PANIC, RICHARD A. MEIER
SNIPPETS:
ICN Pharmaceuticals, Inc. between 5/3/01 and 7/10/02
L for violations of the federal securities laws.
ICN is a researcht prescription and non-prescription pharmaceuticals.
ICN's common stock is traded on
Defendants reported favorable, but false
14 .nflated stock price, certain of the defendants were able to sell 236,833 shares of their
21 Sllass Period quarters to inflate sales.
22 CN shareholder value, compared to the end of 2001.
25 3xchange Act of 1934 and Rule lob-5.
ICN is headquartered in Costa Mesa, California, and conducts business
13 Panic's diligence in developing Ribapharm.
11 to nearly $50 per share as investors were led to expect strong results.
16 shareholders to elect an independent board of directors.
While royalties are always a lower amount than
Schering-Plough later informed the Company that it believed royalties paid
17 losition where a substantial part of its royalties revenue was at risk.
$0.34 in the same period of 2000, above analyst consensus expectations.
14 recognition of millions of dollars in royalties it claimed were due from Schering17
analysts issued reports about ICN.
18 Company a Buy, forecast EPS of $11.40 and $2.15 for 2001 and 2002, respectively,
CIBC World Markets Corp. issued a report initiating 4 coverage on ICN by Matt Geller.
IBecause this was Geller's first report on ICN, he r; J spent time talking to management to
Since Panic still had effecttive control of the board of ICN,
with GAAP are presumed to be misleading and inaccurate,
include disclosure which would be duplicative of disclosures accompanying annual
GAAP, as set forth in FASB Statement of Concepts No. 2,163, states in part:
about the economic resources of an enterprise, the claims to those resources, and
10 Ibout how management of an enterprise has discharged its stewardship responsibility
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