Zoran Corporation Securities Litigation 06-CV-04843-Declaration of Nicole M. Zeiss Re Compliance with Court Order Dated A
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LIONEL Z. GLANCY # 134180 PETER A. BINI~,OW # 173848 2 MICHAEL GOLDBERG # 18 8 669 GLANCY BINKOW & GOLDBERG LLP 3 1801 Avenue of the Stars, Suite 31 1 Los Angeles, CA 90067 4 Telephone : (310) 201-9150 Facsimile : (310) 201-916 0 5 Local Counselfor Lead Plaintiff and the Class 6 LABATON SUCHAROW & RUDOFF LLP 7 CHRISTOPHER J . KELLER ANDREI V. RADO 8 ALAN I. ELLMAN 100 Park Avenue, 12"' Floor 9 New York, New York 10017 Telephone: (212) 907-0700 10 Facsimile: (212) 818-0477 Email: info@labaton .com 11 Lead Counsel for Lead Plaintiff and the Class 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 15 MURRAY ZUCKER, MIDDLESEX ) No. 3 :06-cv-04843-WHA RETIREMENT SYSTEMS, and CAPITALIA ) 1 6 ASSET MANAGEMENT SGR SPA, On Behalf ) CLASS ACTION of Themselves and All Others Similarly Situated, ) 17 Honorable William H. Alsup Plaintiff, ) 18 DECLARATION OF NICOLE M . vs . ) ZEISS RE COMPLIANCE WITH 19 COURT ORDER DATED APRIL 3, 2007 20 ZORAN CORPORATION, UZIA GALIL, ) LEVY GERZBERG, KARL SCHNEIDER, ) 21 RAYMOND A . BURGESS, JAMES D . ) MEJNDL, JAMES B . OWENS, JR., DAVID ) 22 RYNNE, ARTHUR B . STABENOW, ) AHARON AHARON, CAMILLO 23 MARTINO and PHILIP M . YOUNG ) 24 Defendants . ) 25 26 27 28 1 CERTIFICATION OF COMPLIANCE 2 3 1, Nicole M. Zeiss, certify as follows : 4 1 . I am an associate of the law firm of Labaton Sucharow & Rudoff LLP, Lead 5 Counsel for Lead Plaintiff Middlesex Retirement System. 6 2. By Order Re Draft Press Release, dated April 3, 2007, the Court approved the 7 form of a draft press release concerning the dismissal of In re Zoran Corporation See. Litig., 8 No. C 06-04843 (WHA) ("Press Release") and ordered that the press release be disseminated by 9 April 6, 2007. 10 3 . On April 3, 2007, I caused the Press Release to be disseminated by the wire 1 1 service PrimeNewswire, Inc., which transmits press releases on a distribution network that 12 reaches all the major information channels, such as Yahoo.com, MarketWatch.com, Reuters .corn 13 and Bloomberg .com. I have been advised that PrimeNewswire's distribution network reaches 1 4 the same channels as Business Wire, Inc., which was .used to disseminate the initial press release 1 5 at the start of this action . 1 6 5 . On April 3, 2007, I also received confirmation from PrimeNewswire that they had 17 disseminated the Press Release. A copy of the Press Release, as posted on Yahoo.com, is 18 appended hereto. 19 Dated : April 3, 2007 New York, New York 20 21 By: /s/ Nicole M. Zeiss 22 Nicole M. Zeis s 23 24 25 26 27 I 28 CERTIFICATION OF COMPLIANCE CASE No. C 06-04843 WHA EXHIBIT A Labaton Sucharow & RudoffLLP Issues Important Update to Investors in the Common S . .. Page 1 of 2 Yehool My Yahool M" Make Y ! your home page Search : Web Searc h sign ,in l ace Home - nel>a ~--• _V, O.1 F I N A N C E New User? Syn. Up PrimeNewsw .ras Enter Symbol(s) 1Grr GUOTIs Symbol Lookup Finance Searc h sE*T"UME II ScotIfa( ' Related Quote MANDE our, u ZRAN 3-Apr 2 :08pm (C)Yahoc 17 .6 17 .4 Press Release Source: Labaton Sucharow & Rudoff LL P 17 .2 17 .0 16 .0 Labaton Sucharow & Rudoff LLP Issues 10am 12pm 2pm 4pn Important Update to Investors in the Common ZRAN 17.28 +0.28 New 1Lew Detailed Quote Stock of Zoran Corporation Concerning Class Delayed 20 ruins Action Lawsuit Brought On Their Behalf and the Providers - Qlag iaimer Need to Take Prompt Action -- ZRA N Related News Stories Tuesday April 3, 1 :30 pm ET Zoran Demonstrates Newest Set-Top Box and D igi l NEW YORK, April 3, 2007 (PRIME NEWSWIRE) -- Labaton Sucharow & Rudoff Television Technologies for LLP announces this important update to shareholders who may be members of a Manufacturers at CCBN 2007 class that suffered damages as a result of claims alleged in the litigation, In re in China - PR Newswi re (wed mar 28 ) Zoran Corporation Securities Litigation, No . 06-CV-04843 (U .S. District Court for the Zoran Powers Xoceco's New Northern District of California) (Hon . W. Alsup). The action was filed on August 10, Family of China CableSet-Top 2006. Middlesex Retirement System ("Middlesex") was appointed lead plaintiff on )BPS- PR Newswire (Tue Mar 27) behalf of a potential class of investors on December 11, 2006, and was represented • Actel. Bell. Zoran et new deli by Labaton Sucharow & Rudoft LLP ("Labaton Sucharow"), which was appointed warning s - bizjoumais .oom lead counsel on January 4, 2007. (Mon Mar 26 ) . Zoran Receives Second Notice The action was brought as a potential class action on behalf purchasers of the From Nasdaq - AP (Mon mar 26) securities of Zoran Corporation (NasdagGS:ZRAN - Naw$) between August 10, More . 2001 and October 24, 2006, inclusive, and shareholders who received proxy solicitations in years 2004, 2005 and 2006, who allegedly were damaged as a result of defendants' alleged wrongdoing . The Consolidated Second Amended Class - By Industry: Semiconductor - Action Complaint alleged that Zoran, and certain directors and officers of the Specialize d Company, violated Sections 10(b), 14(a) and 20(a) . of the Securities Exchange Act of 1934 by disseminating materially false and misleading statements, including proxy solicitations, that failed to disclose and account for alleged backdating of stock options granted to Zoran's officers and directors, as well as failed to disclose the manipulation of the timing of certain grants of such stock options . Middlesex, however, only alleged an individual claim under Section 14(a) of the Exchange Act, as a result of the 2004 proxy solicitation . Defendants filed a motion to dismiss the action on March 8, 2007 . PLEASE BE ADVISED that on March 20, 2007, lead counsel, on behalf of Middlesex, filed a notice of Top Stories voluntary dismissal of Middlesex's claims with • Stocks Su rge on Home Sales prejudice. As a result, Data, Oil Dip - AP (2:27 pm) Middlesex, as well as • Toyota Sales Rise As Ford, Labaton Sucharow, its Chrysler Fall - AP (2,17 pm) ADVERTISEMENT attorneys, have no w http ://biz.yahoo.com/pz/070403/116741 .html 4/3/2007 Labaton Sucharow & Rudoff LLP Issues Important Update to Investors in the Common S ... Page 2 of 2 abandoned all prosecution . Oil Prices Tumble More Than of this case, Although this action will proceed no La Barre - AP (1 :52 pm) further, shareholders may . Insurers to Get Higher nonetheless file their own M icare Payments - AP (11 :27 i a class or individual action, if am) appropriate, with the Mac re.. assistance of counsel of their own choosing . Lead counsel and Middlesex • Wit-viewed articl note that because of statutes of limitations that apply to the alleged claims, RSS Feeds certain of the claims will become stale and time- Add headlines to your personalized My Yahoo? Page barred as early as eight (About My Yahool and RSS ) months from now if no other lawsuit is filed on ZRAN Headline s these matters. Semiconductor - Specialized More information on this and other class actions can be found on the Class Action Headlines Newsline at bda://www.primenew$wire .comlca More Fin ance RSS Feed s Contact: The Law Firm of Labaton Sucharow & Rudoff LLP Francisco Malonz o (212) 907-086 7 Source: Labaton Sucharow & Rudoff LLP 0 Email Story ' Set News Alert Print SLtou Search News Sponsor Results 1onage - Official Site Don't get gouged by ofd-fashioned phone companies . Risk-free trial. www.vanage.co m Ugly Credit? Attractive Card Rebuild c redit with our MasterCard . Apply online - Instant decisions . www.OrchardBank .com Mortoace R ates Near 40-Yr Lows $310,000 Loan for $099/mo . Think you pay too much? See new payment . www.LowerMyOllls .com (What's This?) Copyright ® 2007 Yahoof Inc. All rights reserved. PtvacyPWjpy - Terms of 5erv rJ g - .Copyright Po Ir - Ad Feedback Copyright ® 2007 P1i_meNews w1re. All rights reserved. Redistribution of this content is expressly prohib ited without prior written consent . PrlmeNewewire makes no claims concerning the accuracy or validity of the Information , and shall not be held liable for any errors, delays, omissions or use thereof. http:/lbiz.yahoo.com/pz/070403/116741 .htmi 4/3/2007 PROOF OF SERVICE BY ELECTRONIC POSTIN G PURSUANT TO NORTHERN DISTRICT OF CALIFORNIA LOCAL RULES AND 2 ECF GENERAL ORDER NO .45 AND BY MAIL ON ALL KNOWN NON-REGISTERED PARTIE S 4 I, the undersigned, say: I am a citizen of the United States and am employed in the office of a member of the Bar of this Court. I am over the age of 18 and not a party to the within action. My business address is 1801 Avenue ofthe Stars, Suite 311, Los Angeles, California 90067. On April 3,2007, 1 served the following by posting such documents electronically to the ECF website of the United States District Court for the Northern District of California : DECLARATION OF NICOLE M . ZEISS RE COMPLIANCE WITH COURT ORDER DATED APRIL 3, 200 7 10 on all ECF-registered parties in the action, and on counsel for the parties in this action, addressed as stated below: 11 12 Ira A. Schochet, Esq. Labaton Sucharow & Rudoff LLP 13 100 Park Avenue, 12`h Floor New York, NY 1001 7 14 15 By Mail: By placing true and correct copies thereof in individual sealed envelopes, with postage thereon fully prepaid, which I deposited with my employer for collection and mailing by the 16 United States Postal Service . I am readily familiar with my employer's practice for the collection and processing of correspondence for mailing with the United States Postal Service.