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1
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COMPLAINT
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EXTRACTED KEY WORDS
KENDALL PLAINTIFFS STOCK ACTS MEMBERS COMMON STOCK MARKET DEFENDANT BURKHARDT SECURITIES REVENUES PRICE DAMAGES SHARES MISLEADING DISSEMINATION INVESTING ALLEGE CENTS FINANCES EXCHANGE ACT PURCHASES PROJECTIONS FACTS RECKLESS EARNINGS PARTICIPATION KOCH OFFICER REPORT |
L RONALD DAIEY AND JOYCE D.
DALEY, JOINTOWNERS, s-FRAUD
Plaintiffs, CLASS ACTION (X&WI&W
V. JURYTRIALDEMANDED
KEINDALL SQUARE mEARcH CORP.,
DR-LK-ANDHENRY
B-T, III
Defendants.
Plaintiffs, individually and on behalf of all other persons similarly situated,
undersigned attorneys, for their complaint, allege upon personal knowledge as to themselves and
their own acts, and upon information and belief as to all other matters, based upon, inter uZi@
investigation made by and through their attorneys, which investigation included, among other
things, a review of the public documents, analyst reports and news releases of Kendall Square
Research Corp. ("Kendall" or the "Company"):
N A
1. Plaintiffs bring this action as a class action on behalf of
other persons who purchased the stock of Kendall on the open market during the Class Period,
as defmed below, to recover damages caused by defendants' violations of the federal securities
laws with regards to the preparation and dissemination to the investing public of false
misleading information.
tlURISDI~ON AND VJSNUE
2. The claims alleged herein arise under Sections 10(b) and 20 of the
Securities Exchange Act of 1934 (the "Exchange Act"), 15 U.S.C. $7Sj(b) and 78t, and Rule lob-
5, 17 C.F.R 5 24O.lOb-5 promulgated thereunder.
3. The jurisdiction of this COLM is based on Section 27 of the Exchange Act,
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2
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CIVIL COVER SHEET
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EXTRACTED KEY WORDS
RESIDE PLAINTIFF COURT DISTRICT SUIT GOVERNMENT USC NATURE CITIZENSHIP SQUARE DEFENDANT DALEY LOCAL RULES RHE SHEET DEMAND JUDGE DRUG MNER INJURY PERSONALPROPERTY PURSUANT STATUTE FOREIGN PTF DEF PARTY ILL LIBERTY PEASE |
JS 44
(Rev. 07m)
VIL COVER SHEET
The J5-U Ciufl Cow +mt and rhe mformauon contaIned herew pelther replace nor wplemenr
,err as required by law. except as prQv,ded by local
rules of Court. This form. approved by ths Judicial
States in September 1974. is resulrcd for rhe use qf rhe
of ~n,r~arlng the cIyI~ dwcket
sheet. (SEE INSTRUCTIONS ON THE REVERSE OF
I (@PLAINTIFFS L. Ronald Daley and Joyce D.
DEFENDANTS
Research cm-p.,
Daley, Joint Owners,
Dr. William I.
III
(b) COUNTY OF RESIDENCE OF FIRST LISTED
COUNTY OF RESIDENCE
MiddleSeX
(EXCEPT IN U.S. PLAINTIFF
ONLY)
NOTE: IN LAND CONDEMNATION
OF THE
TRACT OF LAND
(C) AmORNEYS (FIRM NAME. ADDRESS, AND
A~ORNEYS (IF KNOWN)
-NormanBerman Esq.
Berman, DeVa!Lerio
One Liberty Square
Boston, MA 02109
L
II. BASIS OF JURISDICTION
ofan Ill. CITIZENSHIP OF PRINCIPAL
,P!JCE
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