IN THE UNITED STATE DISTRICT COURT
FOR THE NORTHERN B
DISTRICT OF UlNOlS
EASTERN i?IVISION
MARC ABRAMS, on Behalf of Himself and all; )
Others Similarly Situated,
Plaintiff,
VS.
BAXTER INTERNATIONAL INC., HARRY M.
JANSEN KRAEMER, JR., and BRIAN P. i
ANDERSON, >
> JURY TRIAL DEMANDED
Defendants, ~ 1
CLASS ACTION COMPLAINT
FOR VlOLATlONS OF FEDE/?AL SECURITIES LAWS
Plaintiff has alleged the following based i,rpon the investigation of
which included a review of United States Sec$rities and Exchange Commissibn
filings by Baxter International inc. ("Baxter" or t$e "Company"), as well as
and reports, securities analysts reports and advlisories about the Company, press
and other public statements issued by the ~Company, and media reports about
Company, and plaintiff believes that substantial additional evidentiary suppoftwill
the allegations set forth herein after a raasonqbfe opportunity for discovery.
_NATURE OF T&E ACTION
1. This is a federal class action on behalf of purchasers of
Baxter between January 24,2002 to July 7 8, 2602, inclusive (the "Cfass Period"),
to pursue remedies under the Securities Exchgngs Act of 1934 (the "Exchange Act").
JURISDICTION AND VENUE.
2. The claims asserted herein arise iunder and pursuant to Sections
SNIPPETS:
filings by Baxter International inc.,
and reports, securities analysts reports and advlisories about the Company, press releases
to pursue remedies under the Securities Exchgngs Act of 1934 (the "Exchange Act").
defendants maintain their chief executive offices and principal
place of business within this District.
purchased the securities of Bhxter at artificially inflafed prices during the
maintains its principal executive offices at Onei Baxter Parkway, Deetfieid, Illinois.
Officer and Chairman of the Board of Director$ throughout the Class Period.
did, directly or indirectly, control the conduct of Baxter's business.
releases alleged herein to be misleading, prio): to or shortly after their issuance and had
The members of the Class are so numerous that joinder of all members is
While the exact numb)er of Class members is unknown to Plaintiff
of federal law that is complained of herein
the questions of law and fact common to the @lass are:
used to produce certain types @f dialysis ma@hines.
Baxter's products had risen to 51, including the deaths of two Nebraska residents, The
strong revenue and earnings growth and assurjing the parket that its business,
Medication Deliver-y and EioScience segments bnc.i with sales in the Renal unit in the
driven by additions to its drug delivery aId infugion systems portfolios and growth
performing according to the Company's intern41 forecasts;
contributing cause of the damages sustained by plaint i
prices, thus leading to their losses when the illusion ' as revealed, and the market was
purchasers of Baxter's securities during the C/ass Pe iod suffered similar injury through
Company's securities in an effort to maintair artifici Ily high market prices for Baxter's
securities in violation of Section I Oof the Ex d:hange hct and Rule I Ob-5.
omissions of material facts set forth herein, ore acted 1 Jith reckless disregard for the
Section IOand Rule lob-5 by their acts and omis ions as alleged in this Complaint.
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