UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
________________________________________________
JENNIFER J. FADEM, on behalf of herself and all X No.
others similarly situated, :
: CLASS ACTION
Plaintiff, : COMPLAINT
:
against : JURY TRIAL DEMANDED
:
ELECTRONIC DATA SYSTEMS CORP, RICHARD H. :
BROWN and PAUL J. CHIAPPARONE, :
:
Defendants. :
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Plaintiff, by her undersigned attorneys, individually and on behalf of the Class described
below, upon information and belief, based upon, inter alia, the investigation of counsel, which
includes, among other things, a review of public announcements made by defendants, Securities and
Exchange Commission ("SEC") filings made by defendants, press releases, reports of securities
analysts, and media reports, except as to the paragraph applicable to the named plaintiff which is
alleged upon personal knowledge, brings this complaint (the "Complaint") against defendants named
herein, and alleges as follows:
SUMMARY OF ALLEGATIONS
1. This is a securities class action alleging violations of the federal securities laws
the common law in connection with misstatements and omissions of material fact regarding
Electronic Data Systems Corp. ("EDS" or the "Company") by the defendants named herein. In
SNIPPETS:
Plaintiff, by her undersigned attorneys, individually and on behalf of the Class described
below, upon information and belief, based upon, inter alia, the investigation of counsel,
Exchange Commission filings made by defendants, press releases, reports of securities
the common law in connection with misstatements and omissions of material fact regarding
Electronic Data Systems Corp. ("EDS" or the "Company") by the defendants named herein.
particular, during the class period hereinafter defined, defendants made misrepresentations
C Failing to disclose that EDS's backbone revenue from its Information Solutions IT
outsourcing business is highly susceptible to interruption due to terms in EDS's
outsourcing service contracts with customers without disclosing that payments under
the Securities Exchange Act of 1934 and 28 U.S.C. § 1331.
240.10b-5), and the common law.
exchanged or otherwise acquired the common stock of EDS between
management of this action that would preclude its maintenance as a class action.
whether the federal securities laws were violated by defendants' acts as
The terms of our client contracts generally range from less than one year in the high- value
vulnerability to drops in discretionary spending by customers,
On July 2, 2001, we acquired the airline infrastructure outsourcing business and internal
MISSTATEMENTS AND OMISSIONS OF MATERIAL FACTS
Defendants' made misrepresentations and/or omissions of material fact,
statements issued and disseminated by EDS were materially false and misleading,
making of affirmative statements and reports, or participation in the making of affirmative
members of the Class suffered damages in connection with their purchases of the Company's
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