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2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
All
21
22
23
24
25
26
27
28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
All
21
22
23
24
25
26
27
28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
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Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
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Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
All
21
22
23
24
25
26
27
28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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3
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5
6
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9
10
11
12
13
14
15
16
17
18
19
All
21
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
2 | Patrick J McEnany,Hubert E Huckel,Steven R Miller | {'index': '2', 'text': '\n11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at \nartificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of \nthe alleged corrective disclosures. \n12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at \n355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the \nNASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." \n13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO \nand President. \n14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder \nand one of its directors. \n15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. \n16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as \nthe "Individual Defendants." \nDEFENDANTS\' WRONGDOING \n \nBackground \n Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 \n5 17. Catalyst is a specialty pharmaceutical company which develops and \ncommercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. \n18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase \nwhich is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. \n19. FDA rules permit so-called “compassionate use” – use of a drug that has not been \napproved by the FDA outside of clinical trials. A patient may be given drugs under a \ncompassionate use program if the patient may benefit from the treatment, the therapy can be \ngiven safely outside the clinical trial setting, no other alternative therapy is available, and the \ndrug developer agrees to provide access to the drug. \n20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only \ndozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and \nproviding it to patients through a '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Background
Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20
5 17. Catalyst is a specialty pharmaceutical company which develops and
commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases.
18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase
which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States.
19. FDA rules permit so-called “compassionate use” – use of a drug that has not been
approved by the FDA outside of clinical trials. A patient may be given drugs under a
compassionate use program if the patient may benefit from the treatment, the therapy can be
given safely outside the clinical trial setting, no other alternative therapy is available, and the
drug developer agrees to provide access to the drug.
20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only
dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and
providing it to patients through a
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
All
21
22
23
24
25
26
27
28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
0 | Kevin R. Johnson,Pradeep Sindhu,Robyn M. Denholm,Gene Zamiska | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
1 | Andrew Wilson,Blake J. Jorgensen,Peter Robert Moore,Frank D. Gibeau,Patrick Soderlund | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | From each excerpt, extract the names of the defendants that are individuals.
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Individual defendants: Kevin R. Johnson, Pradeep Sindhu, Robyn M. Denholm, Gene Zamiska
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Individual defendants: Andrew Wilson, Blake J. Jorgensen, Peter Robert Moore, Frank D. Gibeau, Patrick Soderlund
Excerpt: 11. Plaintiff, as set forth in th e attached certification, purchas ed Catalyst securities at artificially inflated prices dur ing the Class Period and has b een damaged upon the revelation of the alleged corrective disclosures. 12. Defendant Catalyst is a Coral Gates, Florida headquartered company located at 355 Alhambra Circle Suite 1500 Coral Gates, FL 33134. The common stock is traded on the NASDAQ Stock Market ("NASDAQ") unde r the ticker symbol "CPRX." 13. Defendant Patrick J. McEnany ("McEna ny") is the Company’s co-founder, CEO and President. 14. Defendant Dr. Hubert E. Huckel M.D. ("Huckel") is the Company’s co-founder and one of its directors. 15. Defendant Steven R. Miller Ph. D. ("M iller") is the company’s COO and CSO. 16. The defendants referenced above in ¶¶ 13- 15 are sometimes referred to herein as the "Individual Defendants." DEFENDANTS' WRONGDOING Background Case 1:13-cv-23878-UU Document 1 Entered on FLSD Docket 10/25/2013 Page 4 of 20 5 17. Catalyst is a specialty pharmaceutical company which develops and commercializes drugs treating orphan (rare) neuromuscular an d neurological diseases. 18. Lambert-Eaton Myasthenic Syndrome (“LEM S”) is an extremely serious disase which is also extremely rare, afflicting about 3.4 persons per million, and about one to two thousand patients in the United States. 19. FDA rules permit so-called “compassionate use” – use of a drug that has not been approved by the FDA outside of clinical trials. A patient may be given drugs under a compassionate use program if the patient may benefit from the treatment, the therapy can be given safely outside the clinical trial setting, no other alternative therapy is available, and the drug developer agrees to provide access to the drug. 20. Jacobus is a tiny privat e pharmaceutical company in New Jersey, with only dozens of employees, and only 35 as of 2009. Jacobus has b een manufacturing 3,4 DAP and providing it to patients through a
Individual defendants: Patrick J McEnany, Hubert E Huckel, Steven R Miller
Excerpt: {{text}}
Individual defendants: | From each excerpt, extract the names of the defendants that are individuals.
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Individual defendants: | ssla_individual_defendants |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
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Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
All
21
22
23
24
25
26
27
28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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7
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14 15 16 17 18
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Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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7
8 9
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14 15 16 17 18
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25
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Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
All
21
22
23
24
25
26
27
28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
All
21
22
23
24
25
26
27
28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
19
20 21 22 23 24
25
26 27 28
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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2 3 4 5 6
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8 9
10 11 12
13
14 15 16 17 18
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Plaintiffs: | ssla_plaintiff |
2 | ['Ruth C May', 'Donna E Ledgerwood'] | {'index': '2', 'text': ' \n1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. \n2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the \nstate of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, \nUnited Kingdom. Through its subsidiaries, it provides various financial services, including \ninvestment bank ing, wealth management, and the offer and sale of securities in this district . \nBarclays PLC has registered the common shares underlying its American Depository Receipts, \nwhich trade on the New York Stock Exchange. It has an obligation to file periodic reports with the \nCommission pursuant to Section 13(a) of the Exchange Act. \n4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or \n“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned \nsubsidiary of Barclays PLC. It provides various financial services, including the offer and sale of \nsecurities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. \nexchanges, each class of which has been registered with the Commission pursuant to Section 12(b) \nof the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to \nSection 13(a) of the Exchange Act. \nIII. \nJURISDICTION & VENUE \n5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under \n28 U.S.C. §§ 1331, 1332, 1367(a). \n6. There is complete diversity of the parties , the amount in controversy exclusive of \ninterest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at \nleast one defendant, and the total amount in controversy for the class exceeds $5,000,000. \n7. Venue is proper in, and Defendants are sub'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas.
2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the
state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London,
United Kingdom. Through its subsidiaries, it provides various financial services, including
investment bank ing, wealth management, and the offer and sale of securities in this district .
Barclays PLC has registered the common shares underlying its American Depository Receipts,
which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the
Commission pursuant to Section 13(a) of the Exchange Act.
4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or
“Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned
subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of
securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S.
exchanges, each class of which has been registered with the Commission pursuant to Section 12(b)
of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to
Section 13(a) of the Exchange Act.
III.
JURISDICTION & VENUE
5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under
28 U.S.C. §§ 1331, 1332, 1367(a).
6. There is complete diversity of the parties , the amount in controversy exclusive of
interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at
least one defendant, and the total amount in controversy for the class exceeds $5,000,000.
7. Venue is proper in, and Defendants are sub
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
0 | ['Not named'] | {'index': '0', 'text': ' \n14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at \nartificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the \nalleged corrective disclosure. \n15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North \nMathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock \nExchange (“NYSE”) under the ticker symbol “JNPR.” \n16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive \nOfficer throughout the Class Period. \n17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief \nTechnology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on \nAugust 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 \nJuniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. \n18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive \nVice President and Chief Financial O fficer throughout the Class Period. \n19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, \nFinance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate \nController through February 26, 2013. \n20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the \n“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS \n4 1 \n2 3 4 5 6 \n7 \n8 9 \n10 11 12 \n13 \n14 15 16 17 18 \n19 \n20 21 22 23 24 \n25 \n26 27 28 '} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at
artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the
alleged corrective disclosure.
15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North
Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock
Exchange (“NYSE”) under the ticker symbol “JNPR.”
16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive
Officer throughout the Class Period.
17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief
Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on
August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500
Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013.
18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive
Vice President and Chief Financial O fficer throughout the Class Period.
19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President,
Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate
Controller through February 26, 2013.
20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the
“Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
4 1
2 3 4 5 6
7
8 9
10 11 12
13
14 15 16 17 18
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20 21 22 23 24
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Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period,
I Executive Vice President of the EA Games Label.
17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
1 | ['Ryan Kelly'] | {'index': '1', 'text': '\t\n10 \t11. \tPlaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period \n11 as described in the Certification attached hereto and incorporated herein by reference and suffered \n12 damages thereon. \t\n13 \t12. \tDefendant Electronic Arts, headquartered in Redwood City, California, develops, \n14 markets, publishes and distributes game software content and services. During the Class Period, \n15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded \n16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed \n17 by scores of stock analysts and stock rating agencies and was constantly in communication with the \n18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst \n19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued \n20 press releases to the financial press. \t\n21 \t13. \tDefendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an \n22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a \n23 director of the Company effective September 15, 2013. \t\n24 \t14. \tDefendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, \n25 I Electronic Arts\' Chief Financial Officer and an Executive Vice President. \t\n26 \t15. \tDefendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, \n27 President of the EA Labels. \n28 \nCOMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 \n2 \n3 \n4 \n5 \n6 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \nAll \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, \nI Executive Vice President of the EA Games Label. \n17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, \nI Electronic Arts\' President and Chief Ope'} | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt: 14. Plaintiff, as set forth in the attached cer tification, purchased J uniper securities at artificially inflated prices dur ing the Class Period and has been damaged upon the revelation of the alleged corrective disclosure. 15. Defendant Juniper is a Delaware corporation with its headquarters located at 1194 North Mathilda Avenue, Sunnyvale, CA 94089. The commo n stock is traded on the New York Stock Exchange (“NYSE”) under the ticker symbol “JNPR.” 16. Defendant Kevin R. Johnson (“Johnson”) has served as the Company’s Chief Executive Officer throughout the Class Period. 17. Defendant Pradeep S. Sindhu (“Sindhu”) is the Company’s Vice Chairman, Chief Technology Officer and Founder. Defendant Sindhu sold 300,000 shares of the Company’s stock on August 2, 2013, less than a week before the FCPA investigation was announced, and also sold 52,500 Juniper shares over three trad ing sessions between January 30, 2013 through February 1, 2013. 18. Defendant Robyn M. Denholm (“Denholm”) ha s served as the Company’s Executive Vice President and Chief Financial O fficer throughout the Class Period. 19. Defendant Gene Zamiska (“Zamiska”) has se rved as the Company’s Vice President, Finance throughout the Class Period. Defendant Zamiska served as the Company’s Corporate Controller through February 26, 2013. 20. The defendants referenced above in ¶¶ 15 – 18 are sometimes referred to herein as the “Individual Defendants.” Case3:13-cv-03733-WHO Document1 Filed08/12/13 Page4 of 20 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiffs: Not named
Excerpt: 10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period 11 as described in the Certification attached hereto and incorporated herein by reference and suffered 12 damages thereon. 13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops, 14 markets, publishes and distributes game software content and services. During the Class Period, 15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded 16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed 17 by scores of stock analysts and stock rating agencies and was constantly in communication with the 18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst 19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued 20 press releases to the financial press. 21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an 22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a 23 director of the Company effective September 15, 2013. 24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period, 25 I Electronic Arts' Chief Financial Officer and an Executive Vice President. 26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period, 27 President of the EA Labels. 28 COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 All 21 22 23 24 25 26 27 28 16. Defendant Patrick Soderlund ("Soderlund") is, and was throughout the Class Period, I Executive Vice President of the EA Games Label. 17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period, I Electronic Arts' President and Chief Ope
Plaintiffs: Ryan Kelly
Excerpt: 1. Plaintiff Dr. Ruth C. May (“May”) is an individual citizen of the state of Texas. 2. Plaintiff Dr. Donna E. Ledgerwood (“Ledgerwood ”) is an individual citizen of the state of Texas. Case 1:23-cv-02583 Document 1 Filed 03/27/23 Page 1 of 142 3. Defendant Barclays PLC is a bank holding company headquartered in London, United Kingdom. Through its subsidiaries, it provides various financial services, including investment bank ing, wealth management, and the offer and sale of securities in this district . Barclays PLC has registered the common shares underlying its American Depository Receipts, which trade on the New York Stock Exchange. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. 4. Defendant Barclays Bank PLC (together with Barclays PLC, “Barclays” or “Defendants”) is a global bank headquartered in London, United Kingdom , and a wholly -owned subsidiary of Barclays PLC. It provides various financial services, including the offer and sale of securities in this district . Barclays Bank PLC has listed a series of corporate debt securities on U.S. exchanges, each class of which has been registered with the Commission pursuant to Section 12(b) of the Exchange Act. It has an obligation to file periodic reports with the Commission pursuant to Section 13(a) of the Exchange Act. III. JURISDICTION & VENUE 5. This Court has federal subject matter jurisdiction under 15 U.S.C. § 77v and under 28 U.S.C. §§ 1331, 1332, 1367(a). 6. There is complete diversity of the parties , the amount in controversy exclusive of interest and costs exceeds $75,000 , at least one member of the proposed class is diverse from at least one defendant, and the total amount in controversy for the class exceeds $5,000,000. 7. Venue is proper in, and Defendants are sub
Plaintiffs: Ruth C May, Donna E Ledgerwood
Excerpt: {{text}}
Plaintiffs: | Extract the name(s) of the plaintiff from the excerpt. If the plaintiff is not named, return "Not named"
Excerpt:
10 11. Plaintiff Ryan Kelly purchased Electronic Arts common stock during the Class Period
11 as described in the Certification attached hereto and incorporated herein by reference and suffered
12 damages thereon.
13 12. Defendant Electronic Arts, headquartered in Redwood City, California, develops,
14 markets, publishes and distributes game software content and services. During the Class Period,
15 Electronic Arts had more than 309 million shares of common stock outstanding, which shares traded
16 in an efficient market on the NASDAQ under the ticker symbol "EA." Electronic Arts was followed
17 by scores of stock analysts and stock rating agencies and was constantly in communication with the
18 markets and investors in quarterly conference calls and frequent presentations to investor and analyst
19 conferences. Electronic Arts also filed periodic public reports with the SEC, and regularly issued
20 press releases to the financial press.
21 13. Defendant Andrew Wilson ("Wilson") is, and was throughout the Class Period, an
22 executive of Electronic Arts, assuming the position of its Chief Executive Officer ("CEO") and a
23 director of the Company effective September 15, 2013.
24 14. Defendant Blake J. Jorgensen ("Jorgensen") is, and was throughout the Class Period,
25 I Electronic Arts' Chief Financial Officer and an Executive Vice President.
26 15. Defendant Frank D. Gibeau ("Gibeau") is, and was throughout the Class Period,
27 President of the EA Labels.
28
COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Case3:13-cv-05837 Document1 Filed12/17/13 Page5 of 251
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17. Defendant Peter Robert Moore ("Moore") is, and was throughout the Class Period,
I Electronic Arts' President and Chief Ope
Plaintiffs: | ssla_plaintiff |
Subsets and Splits