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1 LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 2 WILLIAM S. LERACH (68581) JONAH H. GOLDSTEIN (193777) 3 DAVID W. MITCHELL (199706) 401 B Street, Suite 1600 4 San Diego, CA 92101 Telephone: 619/231-1058 5 619/231-7423 (fax) 6 Lead Counsel for Plaintiffs 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 10 In re BUSINESS OBJECTS S.A SECURITIES ) Master File No. C-04-2401-MJJ LITIGATION ) 11 ) CLASS ACTION ) 12 This Document Relates To: ) CONSOLIDATED COMPLAINT FOR ) VIOLATIONS OF THE FEDERAL 13 ALL ACTIONS. ) SECURITIES LAWS ) 14 DEMAND FOR JURY TRIAL 15 16 17 18 19

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1 JURISDICTION AND VENUE 2 1. Jurisdiction is conferred by §27 of the Securities Exchange Act of 1934 (“1934 Act”). 3 The claims asserted arise under §§10(b) and 20(a) of the 1934 Act. 4 2. Venue is proper in this District pursuant to §27 of the 1934 Act. Defendants maintain 5 corporate headquarters and conduct business at 3030 Orchard Parkway, San Jose, California, 95134, 6 and the wrongful conduct took place in this District.

7 NATURE AND SUMMARY OF THE ACTION 8 3. This is a securities class action on behalf of purchasers of Business Objects S.A. 9 (“Business Objects” or the “Company”) publicly traded securities during the period from April 23, 10 2003 to April 29, 2004 (the “Class Period”). 11 4. Business Objects is a worldwide provider of business intelligence (“BI”) solutions. 12 The Company offers a suite of BI software that includes data integration, query, reporting, online 13 analytical processing, information broadcasting, business alerts for end users, analytic application 14 frameworks and pre-packaged analytic applications. Its software also includes administration tools 15 that enable information technology professionals to set up and deploy the Company’s products 16 across an enterprise. The Company’s software can be deployed in Web, Windows or mobile 17 environments. The Business Objects product line is divided into three families of products: data 18 integration, BI platform and enterprise analytic applications. 19 5. Business Objects had been the leader in the BI solutions market for several years.

20 However, its competitor, Cognos, emerged and challenged Business Objects as the new leader in this 21 industry. Additionally, Microsoft made efforts to break into BI as well. In order to keep its leading 22 status, Business Objects had to become a full service provider of BI solutions. A key step towards 23 this goal was Business Objects’ acquisition of Crystal Decisions Inc. (“Crystal Decisions”) in 24 December 2003, and the integration of that company’s product line. 25 6. Throughout the Class Period, Business Objects reported record results in publicly 26 disseminated press releases and Securities and Exchange Commission (“SEC”) filings, and 27 forecasted positive earnings and revenue targets. Defendants claimed that the Company’s positive 28 results and forecasts were attributable to, in material part, an increase in the Company’s market share

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1 through: (1) the sales of its Enterprise 6 software; and (2) its acquisition of Crystal Decisions. 2 Defendants claimed that there was incredible symmetry and synergies between the two companies, 3 and that Crystal Decisions was “extremely complementary” to Business Objects. Defendants also 4 stated that the acquisition would make the Company the ‘“clear leader in business intelligence, with 5 the largest customer base, the strongest product line, and the highest revenue in the sector.’” 6 Unbeknownst to the class, however, the Company’s apparent success was the result of defendants’ 7 fraudulent scheme to conceal: (1) the Company’s failure to integrate Crystal Decisions, and the 8 defection of many of the Company’s customers/partners to its competitors due to confusion about 9 the synchronization of pricing and new solution bundles; (2) that the Company improperly inflated 10 its balance in deferred revenue due to manipulations in the deferred revenue balance of Crystal 11 Decisions upon acquisition; (3) that the Company had improperly recognized deferred revenues from 12 a backlog of customer contracts, thereby materially inflating the Company’s reported financial 13 results; (4) that the demand for Business Objects’ Enterprise 6 software was less than that reported 14 by the Company, and that the software was unstable and potentially incompatible with other of the 15 Company’s products; and (5) that the Company was experiencing slower than projected revenue 16 growth, including a material drop in European orders and significant sales losses to Microsoft and 17 Cognos. 18 7. On April 29, 2004, after the market closed, Business Objects shocked investors when 19 it released its first-quarter 2004 earnings result of $0.10 per diluted share, which was not only at the

20 bottom of the range previously forecast by defendants, but also significantly lower than analysts’ 21 consensus estimates of $0.15. Moreover, the Company reported disappointing revenues of 22 $217 million and provided second-quarter 2004 guidance of $220 - $225 million in revenues and 23 $0.16-$0.19 per share earnings, which were well below analysts’ consensus estimates of $232 24 million and $0.24 per share, respectively. In reaction to this news, the price of the Company’s 25 American Depository Shares (“ADS”) dropped sharply, by $6.66 or 23.3%, from their closing price 26 on April 29, 2004, to close on April 30, 2004 at $21.92 on unusually high volume. 27 8. The analyst community reported that Business Objects’ disappointing first-quarter 28 results were attributable to various factors. According to analysts at ThinkEquity Partners, Business

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1 Objects’ Enterprise 6 software was experiencing “product stability issues,” and consumers were 2 unaware of Enterprise 6’s incompatibility with the Company’s Business Objects–Crystal Decisions 3 combined product line. Other analysts explained that the Company’s disappointing first-quarter 4 2004 results were attributable to its failure to integrate Crystal Decisions’ product lines and sales

5 force, and to implement a common sales methodology. On April 30, 2004, RBC Capital Markets 6 issued a report pointing to signs of the Company’s integration problems, including “limited financial 7 guidance including the decision to not disclose segmented Crystal Decisions revenues, management 8 departures including the recent departure of the VP-Americas [John Temple], and a slowly evolving 9 product integration strategy.” On the same day, TD Newcrest issued a report stating, “[i]n our 10 opinion, the forward growth implied in the guidance may indicate that [Business Objects] is losing 11 share to [its competitor] Cognos.” Also on that day, Wedbush Morgan issued a report stating: “We 12 remain concerned about the downward revisions to earnings estimates, the lack of visibility into

13 2004 results ... and the prospects of insider sales.” 14 9. On May 4, 2004, Business Objects disclosed in its first-quarter 2004 report, filed with 15 the SEC on a Form 10-Q, that the SEC had commenced an informal inquiry into the Company’s 16 “practices with respect to backlog,” on “customer contracts that have not yet been recognized on a 17 company’s balance sheet or income statement.” Analysts explained that (1) the SEC inquiry related 18 to the Company’s deferred revenue balance, which increased from $136 million in the fourth-quarter 19 of 2003 to $165 million in the first quarter of 2004 following its acquisition of Crystal Decisions;

20 and that (2) the “risk is that [Business Objects] is improperly recognizing revenue from its order 21 backlog rather than simply failing to disclose the value of the backlog.”. 22 10. During the Class Period, while defendants disseminated materially false and 23 misleading information in order to artificially inflate the price of Business Objects’ securities, 24 defendant Bernard Liautaud sold approximately 220,000 shares of his personally-held shares for 25 proceeds in excess of $6 million, causing injury to plaintiff and the other class members.

26 THE PARTIES 27 11. Lead Plaintiff City of Pontiac Policemen’s and Firemen’s Retirement System 28 purchased Business Objects publicly traded securities and was damaged thereby.

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1 12. Defendant Business Objects is a worldwide provider of BI solutions. The Company 2 offers a suite of BI software that includes data integration, query, reporting, online analytical 3 processing, information broadcasting, business alerts for end users, analytic application frameworks 4 and pre-packaged analytic applications. Its software also includes administration tools that enable 5 information technology professionals to set up and deploy the Company’s products across an 6 enterprise. The Company’s software can be deployed in Web, Windows or mobile environments. 7 The Business Objects product line is divided into three families of products: data integration, BI 8 platform and enterprise analytic applications. 9 13. Defendant Bernard Liautaud (“Liautaud”) was at all times relevant hereto, the 10 Chairman and Chief Executive Officer and a director of Business Objects. Defendant Liautaud sold 11 in excess of $6.5 million worth of shares during the Class Period. 12 14. Defendant James Tolonen (“Tolonen”) was at all times relevant hereto, Chief 13 Financial Officer and Senior Group Vice President, Finance and Administration of the Company. 14 15. Defendant John Olsen (“Olsen”) was at all times relevant hereto, President and Chief 15 Operating Officer of the Company. 16 16. Defendants Liautaud, Tolonen and Olsen are referred to herein as the “Individual 17 Defendants.” 18 17. The Individual Defendants are liable for the false statements pleaded herein at ¶¶22- 19 51, as those statements were each “group-published” information, the result of the collective actions

20 of the Individual Defendants. Because of the Individual Defendants’ positions with the Company, 21 they had access to the adverse undisclosed information about its business, operations, products, 22 operational trends, financial statements, markets and present and future business prospects access to 23 internal corporate documents (including the Company’s operating plans, budgets and forecasts and 24 reports of actual operations compared thereto), conversations and connections with other corporate 25 officers and employees, attendance at management and Board of Directors meetings and committees 26 thereof and via reports and other information provided to them in connection therewith. 27 18. It is appropriate to treat the Individual Defendants as a group for pleading purposes 28 and to presume that the false, misleading and incomplete information conveyed in the Company’s

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1 public filings, press releases and other publications as alleged herein are the collective actions of the 2 narrowly defined group of defendants identified above. Each of the above officers of Business 3 Objects, by virtue of their high-level positions with the Company, directly participated in the 4 management of the Company, was directly involved in the day-to-day operations of the Company at 5 the highest levels and was privy to confidential proprietary information concerning the Company and 6 its business, operations, products, growth, financial statements and financial condition, as alleged 7 herein. Said defendants were involved in drafting, producing, reviewing and/or disseminating the 8 false and misleading statements and information alleged herein, were aware or recklessly 9 disregarded, that the false and misleading statements were being issued regarding the Company, and 10 approved or ratified these statements, in violation of the federal securities laws. Defendant Tolonen, 11 as Business Objects’ CFO, was responsible for financial reporting and communications with the 12 market. Defendants Liautaud and Olsen, as Chairman and CEO, and Chief Operating Officer, 13 respectively, were responsible for the financial results and press releases issued by the Company. 14 19. As officers and controlling persons of a publicly-held company whose ADS’s was, 15 and is, registered with the SEC pursuant to the 1934 Act, traded on the Nasdaq National Market 16 during the Class Period and governed by the provisions of the federal securities laws, the Individual 17 Defendants each had a duty to disseminate prompt, accurate and truthful information with respect to 18 the Company’s financial condition and performance, growth, operations, financial statements, 19 business, products, markets, management, earnings and present and future business prospects, and to

20 correct any previously-issued statements that had become materially misleading or untrue, so that the 21 market price of the Company’s publicly-traded securities would be based upon truthful and accurate 22 information. The Individual Defendants’ misrepresentations and omissions during the Class Period 23 violated these specific requirements and obligations. 24 20. The Individual Defendants participated in the drafting, preparation and/or approval of 25 the various public reports and other communications complained of herein and were aware of, or 26 recklessly disregarded, the misstatements contained therein and omissions therefrom, and were 27 aware of theft materially false and misleading nature. Because of their Board membership and/or 28 executive and managerial positions with Business Objects, each of the Individual Defendants had

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1 access to the adverse undisclosed information about Business Objects’ business prospects and 2 financial condition and performance as particularized herein and knew (or recklessly disregarded) 3 that these adverse facts rendered the positive representations made by or about Business Objects and 4 its business issued or adopted by the Company materially false and misleading. 5 21. The Individual Defendants, because of their positions of control and authority as 6 officers and/or directors of the Company, were able to and did control the content of the various SEC 7 filings, press releases and other public statements pertaining to the Company during the Class 8 Period. Each of the Individual Defendants was provided with copies of the documents alleged 9 herein to be misleading prior to or shortly after their issuance and/or had the ability and/or 10 opportunity to prevent their issuance or cause them to be corrected. Accordingly, each of the 11 Individual Defendants is responsible for the accuracy of the public reports and releases detailed 12 herein and is, therefore, primarily liable for the representations contained therein.

13 FALSE AND MISLEADING STATEMENTS ISSUED DURING THE CLASS PERIOD 14 22. On April 23, 2003, the Company issued a press release on Business Wire entitled 15 “Business Objects Reports Record First Quarter Revenue; First Quarter Revenue Up 10% Over Prior 16 Year.” The press release stated in part: 17 Business Objects, the world’s leading provider of business intelligence (BI) 18 solutions, today announced results for the first quarter ended March 31, 2003. 19 First quarter revenues were $118.5 million, an increase of 10 percent over revenues of $107.5 million for the quarter ended March 31, 2002. Net income for the 20 first quarter was $8.8 million, or $0.14 per diluted share, and ADS, compared to net income of $11.0 million, or $0.17 per diluted share and ADS, in the first quarter of 21 the prior year. 22 “Business Objects year-over-year revenue growth and our profitability in the first quarter represent a great achievement, particularly in light of the difficult 23 economic and political environment,” said Bernard Liautaud, chairman and chief executive officer. “We posted strong performances in service revenue, and in 24 analytic applications, where license revenue growth exceeded 100 percent year-over- year.” 25 * * * 26 As of March 31, 2003, the company had $329 million in cash, cash 27 equivalents, and short-term investments. Total assets were $573 million, compared with $552 million at December 31, 2002. 28

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1 * * * 2 Launch of Enterprise 6 3 Today, the company announced the release of Business Objects Enterprise 6, a new version of the company’s industry-leading BI suite. Enterprise 6 provides 4 Business Objects four key competitive advantages: the industry’s best web query, reporting and analysis; the most advanced and complete suite of analytical 5 applications; the best connectivity to packaged applications; and the most integrated BI suite. 6 “Enterprise 6 is the new benchmark of business intelligence. We have 7 received very positive customer feedback, as this new suite supports the requirements of customers who want one standard for their entire enterprise,” said Liautaud. “We 8 believe Enterprise 6 will provide new revenue opportunities, both in new business wins, and with existing customers expanding their deployments.” 9 * * * 10 Business Outlook 11 Management offers the following guidance for the quarter ended June 20, 12 2003: 13 Revenue is expected to be in the range of $119 to $123 million. Diluted earnings per share and ADS are expected to be in the range of $0.14 to $0.18. 14 While the company is not providing detailed 2003 full year revenue or 15 earnings guidance at this time, management plans are to continue to grow overall revenue by approximately 10 percent, but with a greater than 10 percent full year 16 growth in earnings per share. 17 23. This press release was false and misleading as it failed to disclose that Business 18 Objects’ financial results were based on defendants’ improper recognition of deferred revenues from 19 its backlog of customer contracts.

20 24. Following the release of the Company’s April 23, 2003 earnings press release, 21 securities analysts issued reports on Business Objects, which were based on the Company’s false 22 financials and repeated the false information provided by the Company’s senior management. For 23 example, on April 24, 2003 Citigroup Smith Barney issued a report recommending Business 24 Objects’ stock as an “outperform,” stating: 25 We have left our forecasts unchanged for FY03 and FY04 following the 1Q03 results from the company. The revenue performance in the quarter suggests 26 that the company’s FY03 guidance is easily achievable, offering potential upside to both revenue and earnings forecasts. 27 28

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1 25. On May 5, 2003, defendant Liautaud sold 40,000 shares at $22.63-$23.15 per share, 2 for proceeds of $916,000. 3 26. On May 12, 2003 Business Objects filed its quarterly report with the SEC on a Form 4 10-Q. The Company’s Form 10-Q was signed by the Individual Defendants and reaffirmed the 5 Company’s previously announced false financial results. 6 27. On June 26, 2003, the Company issued a press release on Business Wire entitled 7 “Business Objects Ships BusinessObjects Enterprise 6 to More Than 1,500 Customers.” The press 8 release stated in part: 9 Business Objects, the world’s leading provider of business intelligence (BI) solutions, today announced that in the first six weeks since the general availability 10 release of BusinessObjects™ Enterprise 6, Business Objects has shipped the new business intelligence suite to more than 1,500 unique customers. The number 11 represents existing customers spanning 60 countries worldwide who have proactively downloaded the software, or have requested physical shipments of the new business 12 intelligence suite. BusinessObjects Enterprise 6 became generally available on all platforms on May 15, 2003. 13 “We are pleased that customers are showing this degree of interest in our new 14 business intelligence suite,” said Bernard Liautaud, chairman and CEO of Business Objects. “BusinessObjects Enterprise 6 is the industry’s new benchmark for a BI 15 suite – with the best web query, reporting, and analysis, the best packaged application connectivity, the most complete suite of analytic applications, and the 16 best integration across the suite. No other product comes close.” 17 28. On July 18, 2003, the Company issued a press release entitled “Business Objects 18 Reports Preliminary Second Quarter Results.” The press release stated in part: 19 Business Objects, the world’s leading provider of business intelligence solutions, today announced preliminary results for the second quarter ended June 30, 20 2003. The company expects revenue to be in the range of $127 to $129 million, and earnings per share to be between $0.17 and $0.18. 21 Business Objects will report full second quarter results on Thursday, July 31, 22 2003 following the close of the market. (Note: this is a change from the previously scheduled date.) 23 Today, Business Objects also announced its agreement to acquire privately 24 held Crystal Decisions, Inc. (see separate press release). 25 29. This press release was false and misleading as it failed to disclose that Business 26 Objects’ financial results were based on defendants’ improper recognition of revenue from its 27 backlog of customer contracts. 28

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1 30. Also on July 18, 2003, the Company issued a press release on Business Wire entitled 2 “Business Objects Announces Agreement to Acquire Crystal Decisions; Creates the Leading 3 Provider of Enterprise Business Intelligence Solutions.” The press release stated in part:

4 Business Objects and Crystal Decisions, Inc. today announced a definitive agreement under which Business Objects will acquire privately-held Crystal 5 Decisions, the fastest-growing vendor in the business intelligence (BI) market, and the leading provider of enterprise reporting software. 6 Under the terms of the agreement, Business Objects will issue approximately 7 26.5 million shares of common stock in respect of outstanding Crystal Decisions common shares and stock options, which will represent approximately 29 percent of 8 the combined company’s shares. In addition, Crystal Decisions stockholders will receive an aggregate of $300 million in cash. Based on the closing price of Business 9 Objects’ stock on July 17, 2003 the transaction is valued at the aggregate purchase price of approximately $820 million. 10 This transaction joins two of the strongest-performing companies in 11 enterprise software, with highly complementary products, distribution channels, and talent pools. 12 The transaction is expected to be accretive to Business Objects’ 2004 13 earnings even prior to considering the impact of expected revenue and cost synergies, but before purchase accounting adjustments. The companies expect to 14 capitalize on significant growth opportunities resulting from complementary products, channels, and geographic presence. The companies also believe there 15 are significant opportunities for operating cost synergies, which are expected to result in pre-tax savings of approximately $25 million for calendar year 2004. 16 “With this combination, we will seize the opportunity to take a leadership 17 position in the BI market,” said Bernard Liautaud, chairman and CEO of Business Objects. “The two companies are not only successful leaders in their 18 space but have extremely complementary businesses, across many dimensions: product capabilities, distribution channels, international coverage, and skillset. 19 Together, we will become the clear choice for organizations looking to standardize on a single BI provider.” 20 * * * 21 Strategic Rationale 22 The combined company will give Business Objects: 23 - Business intelligence market leadership 24 - The strongest, most complete product line - A powerful range of distribution channels 25 - Significant new growth opportunities

26 Business Intelligence Leadership 27 The combined company will have:

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1 - More than 500 quota-carrying salespeople - More than 1000 customer-facing staff in technical support, education, and 2 professional services - More than 700 alliance partners 3 - More than 16 million licenses 4 The Strongest and Most Complete Product Line

5 By combining the two companies’ product lines, Business Objects will be able to meet the needs of all BI users and provide a strong product offering in all 6 BI market categories. The combined product offering will be the strongest and most comprehensive available in the industry today. 7 Business Objects has long served the “power users” in organizations through 8 its strong ad hoc query, reporting, and analysis capabilities. Business Objects has recently targeted executives with its new dashboard, scorecard, and enterprise 9 performance management (EPM) capabilities, launched earlier this year. Crystal Decisions is the solution of choice for a very large population of report consumers 10 throughout organizations. Together, the two companies will offer a broad product line that meets the needs of all types of enterprises and all types of users. 11 Powerful Range of Distribution Channels 12 The combined company will benefit from unparalleled strength in distribution 13 and will be able to leverage: 14 - Crystal Decisions’ more than 350 OEM partners, including Hyperion, Microsoft, PeopleSoft, and SAP 15 - Crystal Decisions’ reseller, distributor, and inside sales channels 16 - Both companies’ enterprise sales organizations 17 - Business Objects’ relationships with major systems integrators 18 Significant Growth Opportunities 19 Business Objects sees several immediate opportunities for growth: 20 - Product cross-sell. Cross-selling products between the respective 21 companies’ customer bases 22 - Geographic penetration. Leveraging respective geographic strengths, in particular Business Objects’ well established presence in Europe, where enterprise 23 reporting is under-penetrated 24 31. On July 31, 2003, the Company issued a press release entitled “Business Objects 25 Reports Second Quarter Revenue Up 16 Percent; License Revenue Up 3 Percent; Operating Margin 26 Reaches 12 Percent.” The press release stated in part: 27 Business Objects, the world’s leading provider of business intelligence (BI) solutions, today announced results for the second quarter ended June 30, 2003. 28

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1 Second quarter revenues were $129.0 million, an increase of 16% percent over revenues of $111.2 million for the quarter ended June 30, 2002. Net income for 2 the second quarter was $11.5 million, or $0.18 per diluted share and ADS, compared to net income of $11.9 million, or $0.18 per diluted share and ADS, in the second 3 quarter of the prior year. 4 “We are very pleased with our second quarter results, which reflect progress and success on a number of important fronts,” said Bernard Liautaud, chairman and 5 chief executive officer. “In particular, our license revenue showed year-over-year growth, our operating margin improved, we significantly increased the number of 6 contracts over $1 million, and we have seen strong early customer acceptance of the new Enterprise 6 product suite.” 7 Software license revenues in the quarter were $62.7 million, up 3 percent 8 from the same period in the prior year. Software license update and support revenues reached $48.4 million, a 37 percent increase over the same period a year ago, 9 primarily due to continued high levels of customer maintenance renewal. Professional services revenues were $17.9 million, a 20 percent increase over the 10 prior year, driven by a 38 percent growth in consulting revenue. The improvement in consulting revenue reflects an increase in large engagements tied to analytic 11 application deployments. 12 Operating margin in the quarter was 12 percent, compared with an operating margin of 9 percent in the second quarter of the prior year. 13 * * * 14 Major Products Introduced On Schedule 15 New product introductions, delivered on schedule, highlighted the quarter. 16 Enterprise 6, the most complete, fully integrated business intelligence product suite on the market became generally available in May on all major platforms and in seven 17 languages. Enterprise 6 sets the industry standard for web-based query, reporting and analysis, and contains the most advanced suite of analytic applications. In June, 18 Business Objects introduced Performance Manager, a unique solution for advanced goal management, scorecarding, and analysis of metrics. Combined with previously 19 released Dashboard Manager, Performance Manager provides Business Objects customers with important new EPM capabilities. 20 Momentum for Enterprise 6 and Data Integration 21 “The introduction of Enterprise 6 generated excitement and momentum in the 22 marketplace,” said Liautaud. “In the first two months of availability, 73 customers in 10 countries purchased $2.7 million of Enterprise 6 products. In addition, we have 23 seen our win rate increase with the new product suite.” 24 Data Integration products also showed strength during the quarter, contributing $3.1 million in license revenues, a 101 percent sequential increase from 25 the quarter ended March 31, 2003. A total of 40 customers purchased Data Integration products, including 11 contracts over $100,000. 26 License revenues for analytic applications were $5.5 million, up 22 percent 27 from the second quarter of 2002. During the quarter, 63 customers purchased analytic applications, with Dashboard Manager being purchased by twice as many 28 customers as in the first quarter. The license revenue reported for analytic

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1 applications includes only revenue from the analytic products, and does not include data integration or business intelligence license revenue that may be linked to the 2 same contracts. 3 Customer and Contract Highlights 4 The company also reported the following key data for the second quarter: 5 – 438 new customers were added; total customer count now exceeds 18,000; 6 – 7 contracts over $1 million, and 55 between $200,000; and $1 million; 7 – Major customers included America Online, BT Ignite, Ernst & Young, Total, United Utilities Plc, and the U.S. Department of Labor; 8 – Indirect channels contributed 40 percent of license revenue; 9 – At the close of the quarter, the number of quota-carrying sales 10 representatives was 315. 11 Balance Sheet 12 As of June 30, 2003, the company had $363 million in cash, cash equivalents, and short-term investments. Total assets were $617 million, compared with $552 13 million at December 31, 2002. 14 * * * 15 Year-to-Date Results 16 Revenues for the six months ended June 30, 2003 were $247.5 million, compared with revenues in the same period of the prior year of $218.7 million. Net 17 income for the six months ended June 30, 2003 was $20.3 million, or $0.32 per diluted share and ADS, compared with net income for the same period of the prior 18 year of $22.9 million, or $0.35 per diluted share and ADS. The operating margin in the first six months was 10 percent. 19 Business Outlook 20 Management offers the following guidance for the quarter ending September 21 30, 2003: 22 Revenue is expected to be in the range of $121 to $124 million. 23 Diluted earnings per share and ADS are expected to be in the range of $0.14 to $0.17. 24 32. This press release was false and misleading as it failed to disclose that Business 25 Objects’ financial results were based on defendants’ improper recognition of deferred revenues from 26 its backlog of customer contracts. 27 28

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1 33. Following the release of the Company’s July 31, 2003 earnings press release, 2 securities analysts issued reports on Business Objects, which were based on and repeated the false 3 information provided by the Company’s senior management. For example, on August 1, 2003, 4 Wedbush Morgan issued a report recommending Business Objects’ stock as a “buy,” stating: 5 During the second quarter of 2003, Business Objects’ stock had a strong run in anticipation of the benefits it would reap from a significant new-product cycle. 6 While we believed that Business Objects would benefit from the new products, we did not expect to see revenue acceleration until the fourth quarter of 2003 and, thus, 7 considered Business Objects more a 2004 story. We anticipate that continued excitement about the Crystal acquisition and the impressive revenue upside in the 8 second quarter will outweigh potential disappointment from restrained EPS guidance. Our outlook into the fourth quarter and 2004 remains quite favorable; we believe that 9 the acquisition gives Business Objects additional market clout and scale, as well as new flexibility to manage revenue and earnings expectations for 2004. With the 10 stock valuation well below that of Cognos, we think that the risk-reward proposition remains attractive. 11 34. On August 4, 2003, defendant Bernard sold 40,000 shares at $25.25-$26.03, for 12 proceeds in excess of $1 million. 13 35. On August 14, 2003, Business Objects filed it quarterly report with the SEC on Form 14 10-Q. The Company’s Form 10-Q was signed by the Individual Defendants and reaffirmed the 15 Company’s previously announced false financial results. 16 36. On October 23, 2003, the Company issued a press release entitled, “Business Objects 17 Reports Record Third Quarter Revenue up 18 Percent and a Significant Increase in Profitability.” 18 The press release stated in part: 19 Third quarter revenues were $129.1 million, an increase of 18 percent over 20 revenues of $109.9 million for the quarter ended September 30, 2002. Net income for the third quarter was $10.8 million, or $0.17 per diluted share and ADS, up 122 21 percent compared to net income of $4.9 million, or $0.08 per diluted share and ADS, in the third quarter of the prior year. The results in the third quarter of the prior year 22 include approximately $3.3 million of non-recurring expenses related to the acquisition of Acta Technology. 23 The results in the third quarter of 2003 include approximately $1.5 million of 24 additional reported general and administrative expenses resulting from activities directly related to the pending acquisition of Crystal Decisions. 25 “Our performance in the third quarter was outstanding, and reflects the 26 favorable customer response to BusinessObjects Enterprise 6,” said Bernard Liautaud, chairman and chief executive officer. “Enterprise 6 is the key to our 27 improving competitive win rate and growing market share. Importantly, the new suite is compatible with our previous products, so customers can move to Enterprise 28

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1 6 and leverage their earlier investment in Business Objects products. Our operating income improved significantly, as we executed according to plan.” 2 Software license revenues in the quarter were $58.0 million, up 8 percent 3 from the same period in the prior year. Software maintenance revenues, which include license updates and technical support, reached $53.1 million, a 32 percent 4 increase over the same period in the prior year. Professional services revenues were $18.0 million, a 12 percent increase over the prior year, driven by a 22 percent 5 growth in consulting revenue. 6 Operating margin in the quarter was 10 percent, compared with an operating margin of 4 percent in the third quarter of the prior year. 7 Powerful BusinessObjects Enterprise 6 Momentum 8 “We are very pleased with the rapid customer adoption of Enterprise 6,” said 9 Liautaud. “In just the first full quarter of product availability, we achieved the following: 10 – Purchases by 275 customers in 15 countries 11 – $12 million of license revenue, representing approximately 20 percent of 12 total license revenue in the quarter 13 – 27 purchases over $100,000, demonstrating substantial commitment to the new products.” 14 Consistent with the company’s plan for a strong new product rollout, the first 15 upgrade to the suite, BusinessObjects Enterprise 6.1, was delivered as scheduled during the quarter. Enterprise 6.1 provides customers improved analysis for end- 16 users, increased data integration productivity and performance, accelerated analytics, superior enterprise deployability, and end-to-end integration. 17 Continued Growth for Analytic Applications and Data Integration 18 During the quarter, 81 customers purchased analytic application products, 19 contributing $5.7 million in license revenues, up 50 percent from the third quarter of 2002. For the first nine months of 2003, analytic applications license revenues were 20 $18.2 million, up 54 percent over the same period in the prior year. The license revenues reported for analytic applications include only revenues from the analytic 21 products, and do not include data integration or business intelligence license revenues that may be associated with the same contracts. 22 Data Integration products also showed strength during the quarter, 23 contributing $3.9 million in license revenues, a 248 percent increase compared to the third quarter of 2002, which was an abbreviated quarter for sales of data integration 24 products, resulting from the close of the Acta Technology acquisition on August 23, 2002. The result also represents a 23 percent sequential increase from the quarter 25 ended June 30, 2003. A total of 60 customers purchased Data Integration products, including 12 contracts over $100,000. 26 Acquisition of Crystal Decisions Expected to Close in Fourth Quarter 27 The company confirmed that the acquisition of Crystal Decisions is expected 28 to close in the fourth quarter. “Our management has been working closely with

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1 counterparts from Crystal Decisions in a disciplined process to develop integration plans that can be implemented upon closing,” said Liautaud. “We currently have 4 2 task forces and 40 sub-teams dedicated to integration. The planning program is on track and I am very pleased with the progress and level of cooperation between team 3 members.” 4 Significant Growth in All Regions 5 Year-over-year revenue performance in dollars for each region was: Europe grew 22 percent (up 6 percent in Euros), Americas grew 10 percent, Japan grew 12 6 percent (up 11 percent in yen), and Asia- Pacific grew 97 percent. This is the second consecutive quarter in which revenue in Europe increased in local currency. 7 For the third quarter, revenue distribution by region was as follows: Europe 8 49 percent, the Americas 43 percent, Japan 4 percent, and Asia-Pacific 4 percent. 9 Customer and Contract Highlights 10 The company also reported the following key data for the third quarter: 11 – 6 contracts over $1 million, and 50 between $200,000 and $1 million; 12 – 365 new customers were added; total customer count exceeds 18,000 13 – Key customers included Bank of Japan, Daimler Chrysler, Délégation Générale de l’Armement, Kobe Steel, McDonalds UK, U.S. Army, and U.S. 14 Environmental Protection Agency 15 – Indirect channels contributed 43 percent of license revenue 16 – At the close of the quarter, the number of quota-carrying sales representatives was 293. 17 Balance Sheet 18 As of September 30, 2003, the company had $380 million in cash, cash 19 equivalents, and short-term investments. Total assets were $642 million, compared with $552 million at December 31, 2002. 20 * * * 21 Business Outlook 22 The guidance below is for Business Objects current operations on a stand- 23 alone basis, not including any transaction costs, expenses, operations, or increased share count that may result from the acquisition of Crystal Decisions. 24 Management offers the following guidance for the quarter ending December 25 31, 2003: 26 Revenue is expected to be in the range of $144 to $147 million. 27 Diluted earnings per share and ADS are expected to be in the range of $0.25 to $0.28. 28

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1 37. This press release was false and misleading as it failed to disclose that Business 2 Objects’ financial results were based on defendants’ improper recognition of deferred revenues from 3 its backlog of customer contracts. 4 38. Following the release of the Company’s October 23, 2003 earnings press release, 5 securities analysts issued reports on Business Objects, which were based on and repeated the false 6 information provided by the Company’s senior management. For example, on October 23, 2003, 7 Credit Suisse First Boston issued a report recommending Business Objects’ stock as an 8 “outperform,” stating: 9 Q4 guidance of revenues of $144 to $147m and EPS of $0.25 to $0.28 implies license revenue growth of around 10% and at the top of the range operating 10 margins of 17.5% from 13.6% in Q4 2003. We are raising our Q4 revenue forecast from $141.5m to $146.5m. However this is more a function of increased 11 maintenance and services as our license forecast was already for 10% YoY growth. We also maintain our $0.28 EPs forecast. Although with consensus closer to $0.23 12 we believe that there will be consensus upgrades. At his point we leave our 2004 pro forma forecast largely unchanged but would remind investors that our pro forma 13 2004 EPS forecast of $1.15 is dependent on 11% growth from business objects and 20% from Crystal Decisions and a blended operating margin of 16.4%. We continue 14 to believe that these are conservative and may carry upside. As such we retain our outperform rating. 15 39. On November 3, 2003, defendant Bernard sold 40,000 shares at $33.44-$34.04, for 16 proceeds of $1.3 million. 17 40. On November 14, 2003, Business Objects filed its quarterly report with the SEC on 18 Form 10-Q. The Company’s Form 10-Q report was signed by the Individual Defendants and 19 reaffirmed the Company’s previously announced false financial results. 20 41. On December 11, 2003, the Company issued a press release on Business Wire 21 announcing that it had completed its acquisition of Crystal Decisions. In the release, defendant 22 Liautaud commented on the acquisition as follows, in relevant part: 23 “This acquisition creates the clear leader in business intelligence, with the 24 largest customer base, the strongest product line, and the highest revenue in the sector,” said Bernard Liautaud, chairman and chief executive officer. “In terms 25 of product lines, distribution channels, and international presence, the combination of Business Objects and Crystal Decisions is extremely 26 complementary, and delivers strength across the board. We can now offer our customers the de facto standard product in reporting, the market’s leading interactive 27 query and analysis solution, and world-class enterprise performance management products for scorecarding and dashboards,” said Liautaud. 28

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1 42. On January 8, 2004, Business Objects issued a press release over Business Wire 2 introducing its latest version of enterprise reporting, stating, in relevant part, as follows: 3 “Crystal Version 10 will enable us to quickly and easily deploy a BI solution throughout our entire organization,” said Tim Sahouri, vice president of Information 4 Services at Medcor. “Because this is a completely integrated offering, we are not forced to mix and match disparate products to meet our business requirements. 5 Business Objects has done all the planning and integration on the back-end, which means we have much less work to do on the front-end. This allows us to reduce 6 our total cost of ownership by consolidating our BI investments.” 7 43. On the same day, January 8, 2004, Business Objects issued a press release over 8 Business Wire touting its recent acquisition of Crystal Decisions and endorsements received from 9 industry partners. The release elaborated on the purportedly improved Company as follows, in 10 relevant part: 11 Business Objects, the world’s leading provider of business intelligence (BI) solutions, today announced widespread channel and OEM partner support for its 12 acquisition of Crystal Decisions. The new Business Objects offers partners a complete business intelligence suite to meet the full spectrum of BI needs for their 13 customers. In addition, as the clear leader in the BI market, the new Business Objects offers partners a stronger and more robust infrastructure of partner tools 14 to help joint customers obtain a fast return on their business intelligence investments. 15 Channel and OEM partners will benefit from access to industry-leading 16 technology for all categories of business intelligence, including enterprise reporting, ad-hoc query and analysis, and enterprise performance management. In addition, the 17 combined company features the BI industry’s largest research and development organization, providing partners with faster product innovations and additional 18 resources for delivering integrated solutions to the market. 19 The new Business Objects has received key endorsements from a large number of the company’s industry-leading channel and OEM partners .... 20 44. On the same day, January 8, 2004, the Company issued a press release over Business 21 Wire announcing the launch of the newly combined Company, stating, in relevant part, as follows: 22 Business Objects, the world’s leading provider of business intelligence (BI) 23 solutions, today announced the new combined company, resulting from the acquisition of Crystal Decisions, which closed on December 11, 2003. 24 The new Business Objects: 25 –Is the clear leader in the enterprise business intelligence market, with 26 business intelligence revenues more than 50% larger than its nearest competitors in BI license revenues (based on the most recently reported 27 quarters). 28

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1 –Has the industry’s strongest product line with leading offerings in enterprise reporting, ad hoc query and analysis, enterprise performance management, 2 data integration, and analytic applications. 3 –Has nearly 4000 employees serving the needs of customers in 80 countries around the world. Over 2300 of these employees are in customer-facing 4 positions in account management, professional services, and customer support. Over 1000 employees are in product development, making this the business 5 intelligence industry’s largest research and development organization.

6 –Has partnerships with over 1500 industry leaders including system integrators, OEMs, VARs, and distributors. 7 –Has more than 24,000 customers worldwide. 8 As part of the global launch of the new Business Objects, the company has 9 announced: 10 –The availability of the product integration roadmap, which shows in detail how the Crystal and Business Objects product lines will come together over the next 11 few years. 12 –The start of a global multimillion-dollar launch, including an advertising campaign themed around “The Business Intelligence Standard,” and a global 13 road show that will feature live events in 80 cities in 29 countries. As part of this series, the company is hosting a web seminar on January 14th, 2004. 14 Registration for this seminar is available at www.businessobjects.com/clarity. 15 –A San Jose, Calif.-based press conference, happening today, including journalists from around the world. Business Objects will officially launch the 16 company to the media and provide details on the product integration roadmap.

17 –The integration of the two companies’ customer-facing operations. The two companies’ sales, marketing, professional services, alliances, and technical 18 support organizations are now one. In addition, the company’s external websites have been integrated. 19 –A global kickoff in Orlando, Florida the week of January 15th, where over 1300 20 attendees will receive comprehensive training and education to assure that the sales and presales organizations will be prepared to deliver top-level service and 21 guidance to their customers. 22 45. Commenting on the purportedly integrated Company, defendant Liautaud stated, in 23 relevant part as follows: 24 “Today marks the beginning of a new era in business intelligence,” said Bernard Liautaud, chairman and CEO of Business Objects. “We would like to 25 welcome the new employees and customers to the Business Objects family and we look forward to partnering with them as we continue to build a great company that 26 will help our customers achieve stellar results in enterprise performance.” 27 28

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1 46. On February 5, 2004, the Company issued a press release entitled, “Business Objects 2 Reports Record 2003 Fourth Quarter and Year-End Results; Business Objects Standalone Revenue 3 Increases 25 Percent; Operating Margin Reaches 21 Percent.” The press release stated in part: 4 Business Objects, the world’s leading provider of business intelligence (BI) solutions, today announced results for the fourth quarter and year ended 5 December 31, 2003. 6 Fourth Quarter GAAP Results 7 The results for the fourth quarter 2003 include 20 days of revenue contribution and expenses from Crystal Decisions following the close of the 8 acquisition on December 11, 2003; and a number of purchase accounting adjustments and transaction-related expenses which are described in more detail below. 9 Fourth quarter revenues were $184.2 million, an increase of 46 percent over 10 revenues of $126.2 million for the quarter ended December 31, 2002. The net loss for the fourth quarter was $8.6 million, compared to net income of $12.8 million, in 11 the fourth quarter of the prior year. 12 Purchase Accounting Adjustments and Other Transaction-Associated Costs 13 The fourth quarter 2003 GAAP results include certain purchase accounting adjustments and other costs associated with the acquisition of Crystal Decisions, 14 including the following expenses: the write-off of acquired in-process technology of $28.0 million, the amortization of capitalized research and development of $1.0 15 million, the amortization of deferred stock-based compensation of $0.6 million, and the amortization of other intangibles of $0.6 million. 16 The results also reflect restructuring charges of $7.8 million and other one- 17 time integration charges associated with the acquisition of approximately $5.5 million. 18 In addition, the results reflect the elimination of approximately $3.4 million 19 in maintenance revenue during the 20-day period, due to purchase accounting entries eliminating certain purchased deferred revenue. 20 “The business intelligence industry now has an unquestioned leader, and 21 that leader is Business Objects,” said Bernard Liautaud, chairman and chief executive officer. “From the standpoint of license revenue, number of customers, 22 breadth of distribution channels, or product line strength, Business Objects is unsurpassed. Our performance in the fourth quarter reflects this leadership, with 23 strong revenue and operating profit growth from both Crystal Decisions and Business Objects. In a period when the possibility of distraction or customer 24 hesitancy were at their peak, our execution was outstanding.” 25 “Also, we are very pleased with the progress of the integration of Business Objects and Crystal Decisions,” said Liautaud. “Just after the close of the quarter, 26 we presented a product integration roadmap to customers, and the reaction has been very positive. In mid-January we held our combined worldwide sales force 27 kickoff, and the BI industry’s largest sales organization is very enthusiastic about the value proposition it can now offer to clients.” 28

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1 Business Objects Standalone Pro forma Operating Results 2 Had Business Objects and Crystal Decisions operated independently for the entire fourth quarter, the company estimates that the unaudited pro forma operating 3 results for Business Objects would have been as follows ...: 4 – Total revenues of approximately $158 million, up 25 percent from the same period of the prior year 5 – License revenues of approximately $76 million, up 16 percent from the 6 same period of the prior year 7 – Maintenance and support revenues of approximately $60 million, up 38 percent from the same period of the prior year 8 – Professional services revenue of approximately $21 million, up 32 percent 9 from the same period of the prior year 10 – Gross profit of approximately $133 million, up 26 percent from the same period of the prior year. This represents a gross margin of 84 percent 11 – Operating income of approximately $33 million, up 94 percent from the 12 same period of the prior year. This represents an operating margin of 21 percent. 13 A reconciliation of GAAP to pro forma revenue and operating income is included with this press release. 14 Product Line Performance: The performance of key Business Objects 15 product lines during the quarter was as follows: 16 – BusinessObjects Enterprise 6 license revenues were $33 million, a sequential increase of 177 percent from the third quarter of 2003 17 – BusinessObjects Enterprise 6 was included in 649 customer transactions, 18 including 87 transactions over $100,000 19 – Analytic applications license revenues were $7.5 million, compared with $9.1 million the fourth quarter of 2002. For the full year, analytic applications 20 license revenue was $25.7 million, up 23 percent over the prior year. The license revenues reported for analytic applications includes only revenue from the analytic 21 products, and do not include data integration or business intelligence license revenue that may be associated with the same contracts 22 – Data Integration products contributed $5.4 million in license revenues, a 97 23 percent increase compared to the fourth quarter of 2002. A total of 85 customers purchased Data Integration products, including 14 contracts over $100,000. For the 24 full year, Data Integration license revenue was $14.0 million. 25 For Business Objects on a standalone pro forma basis, year-over-year revenue performance for the fourth quarter in dollars for each region would have been: 26 Europe up 36 percent (up 15 percent in Euros), Americas up 7 percent, Japan up 19 percent (up 7 percent in yen), and Asia-Pacific up 202 percent. 27 For the full year, Business Objects standalone pro forma revenue would have 28 been approximately $535 million, up 17 percent over the prior year; pro forma

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1 operating income would have been approximately $70.5 million, up 31 percent over the prior year; and pro forma operating margin would have been 13.2 percent, 2 compared to 11.8 percent in the prior year. 3 Crystal Decisions Standalone Pro forma Operating Results 4 Had Business Objects and Crystal Decisions operated separately for the entire quarter, the company estimates that the unaudited pro forma operating results for 5 Crystal Decisions would have been as follows ...: 6 – Total revenue of approximately $82 million, up 15 percent from the same period of the prior year 7 – License revenue of approximately $51 million, up 9 percent from the same 8 period of the prior year 9 – Gross profit of approximately $65 million, up 15% from the same period of the prior year 10 – Operating income of approximately $13 million, up approximately 13% 11 from the same period of the prior year 12 Combined Company Pro Forma Results 13 The mathematical sum of the two pro forma results would yield the following combined pro forma results for the fourth quarter: 14 – Total revenue of approximately $240 million 15 – License revenue of approximately $127 million 16 – Operating income of approximately $46 million; an operating margin of 19 17 percent 18 Balance Sheet 19 As of December 31, 2003, the company had $235 million in cash and cash equivalents. Total assets were $1.8 billion. 20 Business Outlook Management offers the following guidance for the quarter 21 ending March 31, 2004: 22 – Revenue is expected to be in the range of $208 million to $218 million 23 – GAAP diluted earnings per share and ADS are expected to be in the range of $0.03 to $0.09 24 – Non-GAAP pro forma diluted earnings per share and ADS are expected to 25 be in the range of $0.10 to $0.16. 26 Both the GAAP and non-GAAP guidance exclude eliminated deferred maintenance revenue of approximately $12.6 million, as detailed on the below 27 supplemental schedules, which is approximately a $0.08 per share and per ADS reduction reflected in both estimates. 28

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1 The non-GAAP earnings per share and ADS also excludes purchase accounting adjustments and other transaction-associated or restructuring costs of 2 approximately $10 million, as detailed on the below supplemental schedules, which is approximately a $0.07 per share increase reflected in this estimate. 3 47. This press release was false and misleading as it failed to disclose that Business 4 Objects’ financial results were based on defendants’ improper recognition of deferred revenues from 5 its backlog of customer contracts. 6 48. Following the release of the Company’s February 5, 2004 earnings press release, 7 securities analysts issued reports on Business Objects, which were based on and repeated the false 8 information provided by the Company’s senior management. For example, on February 6, 2004, 9 Pacific Crest Securities, Inc. issued a report which recommended Business Objects stock as a “buy,” 10 stating: 11 “Business objects has new products, the potential for further cost reductions, 12 tremendous earnings leverage, a hot industry segment and a reasonable valuation. We reiterate our Buy rating.” 13 49. On February 20, 2004, defendant Liautaud sold 100,000 shares at $32.15-$32.49, 14 reaping $3.2 million in proceeds from this sale which predates the SEC investigation by eight weeks. 15 50. On March 12, 2004, Business Objects filed its annual report with the SEC on Form 16 10-K. The Company’s Form 10-K was signed by the Individual Defendants and reaffirmed the 17 Company’s previously announced false financial results. 18 THE TRUTH EMERGES 19 51. On April 29, 2004, after the market closed, Business Objects shocked investors when 20 it issued a release on Business Wire announcing its first-quarter 2004 results. In the release, the 21 Company reported earnings of $0.10 per diluted share, which was not only at the bottom of the range 22 previously forecast by defendants, but also significantly lower than analysts’ consensus estimates of 23 $0.15. Moreover, the Company reported disappointing revenues of $217 million and provided 24 second-quarter 2004 guidance of $220 - $225 million in revenues and $0.16 - $0.19 per share 25 earnings, both of which were well below analysts’ consensus estimates of $232 million and $0.24 26 per share, respectively. In the release, the Company stated as follows, in relevant part: 27 Business Objects, the world’s leading provider of business intelligence (BI) 28 solutions, today announced results for the first quarter ended March 31, 2004. The

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1 results for the first quarter of 2004 include the first full quarter of the former Crystal Decisions operations following the close of the acquisition on December 11, 2003. 2 First quarter revenues were $217.2 million, an increase of 83 percent over the 3 first quarter of 2003. First quarter license revenue of $114.5 million represented a 104 percent increase over the first quarter of the prior year. 4 “I am pleased with our results in the first quarter, especially given the 5 inherent challenge of integrating two large, successful BI companies,” said Bernard Liautaud, chairman and chief executive officer. “Our employees have done an 6 outstanding job in bringing these two companies together. Our growth primarily reflects the ongoing integration of Crystal operations, and a positive customer 7 response to our combined product portfolio.” 8 “These results clearly establish Business Objects as the number one vendor in Business Intelligence. We believe that our market leadership combined with our 9 world-class, proven products in query, reporting and analysis, performance management, and data integration make Business Objects the clear choice in the BI 10 market, particularly for organizations making enterprise BI standardization decisions.” 11 Operating income based on US GAAP was $9.3 million, an operating margin 12 of 4 percent. Pro forma operating income in the quarter was $19.2 million, an operating margin of 9%. Pro forma results differ from US GAAP as they exclude 13 certain purchase accounting adjustments and other costs associated with the acquisition of Crystal Decisions. A reconciliation of US GAAP to pro forma results 14 in included at the end of this release. 15 Net income based on US GAAP was $3.3 million, or $0.04 per diluted ordinary share and ADS. Pro forma net income of $9.4 million, or $0.10 per diluted 16 ordinary share and ADS. 17 * * * 18 Net income was adversely impacted by approximately $6.8 million of non- operating currency exchange losses included in other income and expense, which 19 represents an adverse impact of $0.05 per diluted ordinary share and ADS. These losses were primarily caused by the effect of a stronger US dollar on euro- 20 denominated intercompany loans, which occurred as part of the integration process. Business Objects does not expect such losses to be recurring. 21 * * * 22 Business Outlook 23 Management offers the following guidance for the quarter ending June 30, 24 2004: 25 –Revenue is expected to be in the range of $220 million to $225 million 26 –US GAAP diluted earnings per ordinary share and ADS are expected to be in the range of $0.07 to $0.10 27 –Pro forma diluted earnings per ordinary share and ADS are expected to be 28 in the range of $0.16 to $0.19.

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1 52. In reaction to this news, the price of Business Objects’ ADS’s dropped dramatically,

2 falling $6.66 or 23.3% from its closing price on April 29, 2004, to close on April 30, 2004 at $21.92, 3 on unusually high volume. 4 53. The analysts commonly expressed surprise and disappointment at the undisclosed 5 material information withheld by the Company. On April 30, 2004, Wedbush Morgan issued a 6 report stating in part:

7 x Yesterday, Business Objects reported mixed first quarter of 2004 results – revenue of $217 million was just ahead of the $216 million consensus, while proforma EPS of 8 $0.10 fell well short of the $0.15 consensus. The EPS shortfall was largely caused by foreign exchange translation expenses, which resulted in other expenses of $4 9 million versus our expectations for income of $3.5 million.

10 x Guidance was disappointing relative to consensus. The company indicated it was concerned about the pipeline and weakness in the Americas. The company expects 11 somewhat lower-than-consensus revenue for the second quarter and full year 2004, while it expects substantially lower-than-expected EPS for the second quarter. 12 x We have lowered our Q2 revenue estimate from $233 mil. to $227 mil. and our EPS 13 estimate from $0.23 to $0.19. We are establishing a 12-month price target of $28, in line with the peer company PE multiple of 22x. 14 x We remain concerned about the downward revisions to earnings estimates, the lack 15 of visibility into 2004 results, integration challenges, and the prospects of insider sales. As such, we believe that the stock reflects fair value at a PE valuation of 22x 16 our 2005 estimate, which we consider in line its peer companies. Thus, we maintain our Hold rating on Business Objects. 17 54. On that same day, JP Morgan issued a report stating in part: 18 License Revenue Inline; North America Softer than Expected 19 Business Objects posted $114M in license revenue, ahead of our $112M 20 estimate, but not the degree of upside we had seen in previous quarters as the US Dollar strengthened against the Euro during the quarter. Reported pro-forma EPS of 21 $0.10 included a $6.8 M negative foreign exchange impact surrounding the financing of the Crystal acquisition, so adding an additional $0.05 EPS from this one-time 22 charge put $0.15 EPS ahead of our $0.14 estimate and inline with $0.15 First Call mean. Total license growth was up 12% YoY on an apples-to-apples compare 23 combining Crystal license revenue, with roughly half this gain coming from positive foreign exchange impact. Revenue in North America was lighter than expected, 24 with organic growth of 7% YoY, versus internal growth of 13% overall. The BOBJ/Crystal sales force integration was plagued by a greater amount of account 25 overlap in the US, resulting in many sales reps working with new accounts and having to build up pipeline. In addition, the head of US sales Jon Temple, 26 announced his resignation and will be replaced by COO John Olsen as acting head of US sales until a replacement is announced. 27 55. On April 30, 2004, SG Cowen issued a report, stating in part: 28

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1 x Although Q1 results were at the top end of the range, guidance for Q2 has surprised the market, Q2 guidance of sales of $220m to $225m compares with our forecast of 2 $230m. Earnings guidance of 16c to 19c compares with our forecast of 24c suggesting at least 5c downside to our full year forecast of $1.06. 3 x The main reason for the weak guidance seems to be due to the ‘challenge’ of 4 integrating the Bobj salesforce with that of Crystal in the US. However, management did suggest that there would be an H2 ‘pay-off’ from this which leads 5 us to believe that it would be wrong to significantly cut our H2 numbers. We therefore would not expect to cut our full year earnings by any more than 10% which 6 suggests that the 20% fall in the share price is an over-reaction.

7 x As flagged by us before the numbers, management failed to give any meaningful information on the performance of Crystal and this may be causing investors to 8 expect the worst. Our view is that growth at Crystal has slowed from the near 30% rate pre-acquisition and has been close to 10% in the last 2 quarters. While some 9 may be disappointed with this, it is still above the rate being achieved by the rest of the Group and should improve in H2 once the salesforce issue is resolved. 10 x We will be reviewing our EPS numbers. 11 56. On April 30, 2004, Morgan Stanley issued a report, stating in part: 12 1Q04 earnings came in below our forecasts and at the low end of the 13 guidance range. License revenue was $114 million, below our $118 million estimate, but still around 6% organic constant currency growth and not so different 14 from competitor growth rates. Normalized EPS was $0.19 compared with our forecast of $0.24, but variance of $0.04 was due to one-off negative finance income. 15 Guidance was weak and we think there are two forces at play. First, Crystal’s 16 deceleration in 4Q03 now looks to be trend rather than anomaly. We estimate that Crystal has grown by around 10% YoY for 2 quarters in a row. No disaster, but well 17 lower than the 26-28% growth rate it posted through the first three quarters of last year. Second, the company is dealing with the integration of two highly 18 overlapping sales forces in the US. We think the company has now set a realistic growth outlook. We are forecasting lower organic license revenue growth for the 19 remainder of the year (5%) compared to 1Q04 (12%). Given the improving demand for Business Intelligence software, if the company can reinvigorate the US sales 20 organization we think it has a shot at beating our forecast growth rate. But it will probably take a couple of quarters before we see evidence of this. 21 57. On April 30, 2004 Nate Swanson and Jason Somrock, analysts at ThinkEquity 22 Partners, issued a report entitled “No Soup For You!” in which they lowered their price target based 23 on Business Objects’ first quarter 2004 results and projections. In the report, Swanson and Somrock 24 stated, in relevant part, as follows: 25 Crystal business seems to have lost momentum domestically. Prior to the merger, 26 Crystal had been posting y/y license revenue growth of +25%, but post merger we estimate that growth has slowed to the 8% – 13% range .... 27 x Business Objects posted 1Q revenue that was inline with our $217M estimate, 28 while EPS of 10c fell short of our 16c estimate. Although it’s difficult separate

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1 the BO and Crystal businesses, we believe the Enterprise 6 upgrade cycle is in full swing and performing relatively well, while the Crystal business seems to 2 have lost momentum domestically. Prior to the merger, Crystal has been posting y/y license revenue growth of +25%, but post merger we estimate that growth has 3 slowed to 8% – 13% range. We are especially troubled by the lack of momentum in the Crystal business, as we had reduced our Crystal revenue expectations 4 following disappointing 4Q’03 results. 5 * * *

6 x While we believe the E6 upgrade cycle and associated maintenance renewals (catch-up) have significant momentum, we continue to hear of product stability 7 issues, although the recent 6.1b release, which is a bug-fix release over 6.1a, seems to be markedly improved. 8 x Our channel checks indicate that most Business Objects customers who are 9 upgrading to E6 (which is a substantial upgrade) are not aware that the core of the future Business Objects-Crystal product line will be based upon Crystal 10 Enterprise, nor the likely reality that they will need to migrate from an E6-based system to a Crystal Enterprise system at some point in the future. 11 58. On the same day, T.D. Newcrest issued a report on Business Objects emphasizing 12 that the Company faced significant challenges in integrating Crystal Decisions. The report stated in 13 relevant part, as follows: 14 Business Objects’ acquisition of Crystal Decisions represents the cross-border 15 integration of a firm virtually equal its size, competing in many duplicate product areas. Although management should be congratulated for operating as one 16 company from day one, integration of the North American sales force is causing lower visibility as the new merged team learns to operate with a common sales 17 methodology and in some case builds a new pipeline of business. Additionally, U.S. executive John Temple has left the company, a gap that will be filled by C.O.O. 18 John Olsen. 19 * * *

20 Organic License Growth Regresses From Q4/03 Levels. Revenue growth (pro forma) of approximately 13% was partially the result of positive currency 21 impacts. We estimate that year-over-year constant-currency license growth was only 5.4%, a decline from 7-8% of Q4/03 and a disappointment considering the deals that 22 had slipped into Q1 from Q4. 23 * * * 24 On a pro forma basis, Crystal and Business Objects would have generated $113.2 million of license revenues in Q2/03, leading to our calculation that the 25 guidance range anticipates year-over-year pro forma license growth of between 0% and 4%. Given the year-over-year currency effects would still be positive, this 26 guidance is indeed very low. With this guidance range for Q2/04 together with our estimate of 5.4% growth in Q1/04, we believe that Business Objects is in fact losing 27 market share (Cognos’ February/04 adjusted growth rate was 7%, and our model forecasts organic (but adjusted for currency) growth of 11.8%). 28

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1 59. On April 30, 2004, Bloomberg issued a report entitled, “Business Objects Plunges as 2 Profit Misses Forecasts.” The article stated in part: 3 Shares of Business Objects SA, whose software helps companies analyze database information, plunged as much as 22 percent after first-quarter profit fell, 4 coming in at the lower end of its target range and missing analyst forecasts. 5 Shares of the company dropped as much as 5.2 euros to 18.9 euros and traded at 19.7 euros as of 1:58 p.m. in Paris. The company’s American depositary receipts 6 yesterday rose 4.3 percent to $28.58 on the Nasdaq stock market. 7 Business Objects “disappointed heavily on profitability,” CDC Ixis analysts Gwenael Giard and Brice Thebaud wrote in a note. They lowered their 8 recommendation on the shares to “add” from “buy” and cut their price forecast 15 percent to $31.20. 9 Net income fell to $3.3 million, or 4 cents a share, from $8.8 million, or 14 10 cents, a year earlier, the Levallois-Perret, France-based company said in a statement sent on Business Wire yesterday. That’s lower than the 15 cents predicted by 27 11 analysts in a Thomson Financial survey, and at the lower end of the company’s February forecast range of 3 cents to 9 cents. 12 Profit was hurt by non-operating currency exchange losses of $6.8 million, or 13 5 cents a share, the company said. The losses were caused by the effect of a stronger U.S. dollar on euro-denominated loans within the company as part of the integration 14 of Crystal Decisions Inc., bought in December for $1.2 billion in cash and stock.

15 POST-CLASS PERIOD REVELATIONS 16 60. On May 4, 2004, Business Objects filed with the SEC its first-quarter 2004 report on 17 a Form 10-Q, reiterating the results announced in its April 29, 2004 press release. In addition, the 18 Company revealed that the SEC had commenced an inquiry into its backlog, stating in relevant part, 19 as follows:

20 The Securities and Exchange Commission has initiated an informal inquiry which we believe relates to backlog. We are cooperating fully with the Securities and 21 Exchange Commission. While we believe our practices are proper and in accordance with generally accepted accounting principles in the United States, we can give no 22 assurance as to the outcome of this inquiry. 23 61. On May 5, 2004, it was reported on CBSMarketWatch.com that, “Business Objects 24 falls on SEC inquiry.” The article stated in part: 25 Business Objects’ Nasdaq-traded shares fell as much as 4 percent Wednesday after the company said the Securities and Exchange Commission is looking into its 26 “practices with respect to backlog.” 27 “While we believe our practices are proper and in accordance with generally accepted accounting principles in the United States, we can give no assurance as to 28

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1 the outcome of this inquiry,” the software maker said in its first-quarter regulatory filing. 2 The maker of ...business intelligence software used to mine corporate data, 3 with headquarters in both San Jose, Calif., and Paris said ... its executives are “cooperating fully” with the SEC. 4 Analysts at J.P. Morgan told clients that the inquiry may be related to the 5 company’s deferred revenue balance, and additions to that balance created by Business Objects’ acquisition of Canada-based business-intelligence software 6 maker Crystal Decisions late last year. 7 Business Objects first-quarter net income and earnings excluding one-time items excluded $12.6 million of software maintenance revenue due to purchase 8 accounting write-offs related to Crystal. Analysts had anticipated that exclusion and included it in their estimates. 9 J.P. Morgan told clients that the announcement is not expected to affect 10 operations, but said the inquiry could add to investor concerns about the integration of Crystal Decisions. 11 In its first quarter conference call, company executives took a more 12 negative tone related to Crystal. Analysts at Schwab SoundView said that Business Objects is “struggling to integrate the two businesses.” 13 On a conference call with analysts, executives with the company said late last 14 month they would no longer be breaking out results from Crystal Decisions, making it difficult, if not impossible for investors and analysts to track performance of the 15 Crystal business. 16 Also of note in Business Objects’ first-quarter regulatory filing is that the company said it entered into forward exchange contracts to purchase U.S. dollars, 17 Canadian dollars and pounds in exchange for euros, in an effort to mitigate the risk of currency losses. 18 “We believe we have contained the majority of the exposure related to our 19 most material inter-company loans using this strategy,” the company said in its SEC filing. 20 Business Objects said late last month that first-quarter net income was 21 adversely affected by about $6.8 million in non-operating currency exchange losses, which lowered results by 5 cents a share. Most was related to asset transfers and 22 inter-company loans associated with Crystal. 23 62. Then, on that same day, as news was leaking (and the Company’s stock was sinking), 24 defendant Liautaud sold another 100,000 shares between $21.65 and $22.11 per share, for proceeds 25 in excess of $2.1 million. 26 63. On August 4, 2004, the Individual Defendants caused the Company to issue a press 27 release entitled “Business Objects Provides Regulatory Update.” The press release stated in part: 28

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1 Business Objects announced that today the Securities and Exchange Commission notified the Company by means of a Wells notice that it intends to recommend to the 2 Commission that a civil action be initiated against Business Objects alleging that the Company violated provisions of the Securities and Exchange Act of 1934 relating to 3 periodic reporting requirements. The Company had previously disclosed the staff’s informal inquiry. 4 The Company believes that the staff’s inquiry addresses the fact that the 5 Company does not disclose its backlog of unshipped orders, and that the inquiry does not involve revenue recognition issues. The Company believes its disclosures 6 are compliant with the security laws and are consistent with industry and general practice with respect to disclosing backlog. 7 * * * 8 The Company intends to vigorously defend its position in this matter. 9 64. On August 4, 2004, it was reported on CBSMarketWatch.com that “Business Objects 10 may be sued by SEC French software maker’s backlog accounting questioned.” The article stated in 11 part: 12 In recent trading, the company’s U.S.-listed shares dropped 5.7 percent to 13 $19.53. In Paris, the shares lost 7 percent to 16.26 euros. 14 Analysts said the risks for the company were centering on a fine it may have to pay. The company, which develops software used to mine corporate data, first 15 disclosed the SEC inquiry in a filing in May.

16 “Clearly, the risk is that BOBJ is improperly recognizing revenue from its order backlog, rather than simply failing to disclose the value of the backlog,” Bear 17 Stearns analysts told clients. 18 “If this is the case, the BOBJ management will either have been fraudulent or negligent. This is not the case in our opinion. Either way, the specter of the SEC 19 enquiry will retain pressure on the shares until resolved.”

20 A software industry analyst in Paris said, “The concern is on the backlog disclosure; they will not have to restate previous revenue.” 21 Business Objects, providing more detail on the scope of the SEC inquiry, said 22 it believed the U.S. regulator is addressing “the fact that the company does not disclose its backlog of unshipped orders.” 23 The company, which also has offices in San Jose, Calif., said that the inquiry 24 doesn’t involve revenue recognition issues. 25 Business Objects said it received a Wells notice from the SEC, which signals that the SEC staff plans to recommend civil action against the company. It said none 26 of its officers or directors would be named as defendants. 27 Currently, Business Objects provides investors with a sense of its backlog of unshipped orders by indicating whether license sales over the near-term quarter will 28 increase or decline, analysts said.

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1 Business Objects said it believes its disclosures are compliant and “are consistent with industry and general practice with respect to disclosing backlog.” It 2 plans to defend its position. 3 With more disclosures on the backlog, it should be easier for investors to predict trends in license sales. 4 On Monday, Business Objects shares tumbled 6 percent in Paris to 16.78 5 euros after Goldman Sachs said it placed 5.75 million shares at 16.90 euros per share on behalf of venture investors Silver Lake Partners. The investor group still owns 6 15.8 million shares, according to a regulatory filing. 7 65. Also on August 4, 2004 it was further reported on TheStreet.com that “Business 8 Objects Gets Wells Notice.” The article stated in part: 9 Business Objects dropped sharply Wednesday after the vendor of business intelligence software disclosed that the Securities and Exchange Commission is 10 likely to file civil charges over the company’s disclosure practices. 11 Shares of the French-owned firm closed down 97 cents, or 4.7%, to $19.73. 12 In a press release early Wednesday, Business Objects said it received a Wells notice indicating the SEC staff will recommend a civil proceeding against the 13 company unless it is convinced otherwise. The complaint will focus on Business Objects’ practice of not disclosing its backlog of unshipped orders, the company said. 14 But according to several accounting experts, it’s possible the issue speaks to 15 management’s alleged failure to disclose material information to investors required by the Sarbanes-Oxley Act and the SEC’s management discussion and 16 analysis rule. 17 In any case, an investigation of this nature by the SEC “creates a very bad impression and is likely to be an overhang on the stock,” said Pacific Crest analyst 18 Brendan Barnicle, who downgraded the stock when the issue first surfaced in April in a one-sentence disclosure in the company’s 10-K SEC filing. 19 The April disclosure was buried under a barrage of other bad news when the 20 company announced first-quarter earnings that missed Wall Street estimates by a wide margin, sending the stock into a one-day plunge of 23% that has never been 21 made up. 22 * * * 23 Business Objects, along with other enterprise software companies, doesn’t recognize revenue until a product is actually shipped to a customer. If a product has 24 been sold but not shipped – perhaps because the company has not yet completed its credit check of new customers, or because a last-minute technical glitch needs to be 25 fixed – the sale then becomes backlog until it is sent to the customers, said Don Markley, the company’s senior director of investor relations. 26 If a sale happened late in the quarter and the software wasn’t shipped until the 27 next quarter, but the company recognized the revenue in the earlier quarter, that would constitute a regulatory violation. But Markley said that the SEC told Business 28 Objects that revenue recognition is not at issue.

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1 The company denied doing anything improper, and said in its Wednesday statement that it “intends to vigorously defend its position in this matter.” 2 While there is no requirement to merely disclose backlog, Jeff Brotman, a 3 professor of accounting at the University of Pennsylvania, said if “the backlog was related to a material issue and that issue was not disclosed, it could be a violation 4 of the management discussion and analysis (MD&A) rule.” Moreover, Sarbanes- Oxley requires executives to certify that financial statements are true and accurate 5 in all material aspects, not just true according to generally accepted accounting principles, Brotman said in an interview. 6 DEFENDANTS’ FRAUDULENT SCHEME 7 66. As set forth in ¶¶22-51, defendants made materially false and misleading statements 8 in order to artificially inflate the price of Business Objects’ stock, while at the same time defendant 9 Liautaud reaped over $6.5 million in insider sales. 10 67. During the Class Period, defendants actively concealed from shareholders its failure 11 to integrate Crystal Decisions’ product line and sales force, and the incompatibility of Business 12 Objects’ products, including Enterprise 6 with the Company’s Business Objects/Crystal Decisions’ 13 combined product line. 14 68. According to a former Business Objects Senior Director of Customer Technical 15 Support, who worked at the Company during the Class Period, the Company knew that customer 16 orders were being delayed and cancelled because of product integration problems between Business 17 Objects and Crystal Decisions. Customers were confused about what products and services they 18 would receive from the integrated company. This resulted in customers going to Business Objects’ 19 competitors. Even more troubling than the customer confusion over products were the technical 20 issues that customers were experiencing as a result of the merger of the two companies’ products. 21 Certain Crystal Decisions products were not compatible with the customers’ Business Objects 22 products. This also resulted in Business Objects’ customers going elsewhere. 23 69. A former Crystal Decisions employee who served as a Telecommunications Analyst, 24 Project Manager at Crystal Decisions during the Class Period stated that when the acquisition was 25 announced, teams from the two companies were not allowed to integrate or even share information. 26 According to a former Business Objects employee who was Vice President of Product Strategy 27 during the Class Period, product coordination and product overlap became an important issue for the 28

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1 integrated company because product partners Microsoft and SAP bundled their software with 2 Business Objects and Crystal Decisions software. Given that reality, the lack of integration posed a 3 unique and serious obstacle. 4 70. During the Class Period, defendants also actively concealed from investors that they 5 had improperly recognized revenue from a backlog of customer contracts and manipulated the 6 deferred revenue balance of Crystal Decisions upon acquisition. These improper acts materially 7 inflated the Company’s deferred revenue balance, which reported financial results for 2003, and 8 defendant Liautaud took advantage of over $6.5 million in insider sales. 9 71. According to a former Senior Director, the Vice President of Business Objects’ 10 Alliance Group admitted that some sales were not recorded in the quarter in which they were made. 11 In another case, an employee met with defendant and Chief Operating Officer John Olsen to insist 12 that an IBM order be shipped before the end of the quarter, rather than in the following quarter, as 13 the Company’s shipping department had been instructed, IBM insisted the shipment be made before 14 the end of the quarter so that it could properly recognize revenue from its sale to its customer that 15 quarter. The Company made the shipment by the end of the quarter but did not recognize the 16 revenue until the following quarter. 17 72. To overstate its revenues, net income and earnings per share (“EPS”) during the Class

18 Period, Business Objects violated Generally Accepted Accounting Principles (“GAAP”) and SEC 19 rules by failing to properly report its Class Period financial results. The fiscal year 2003 results were 20 included in a Form 10-K and Form 10-Qs filed with the SEC. The results were also included in 21 press releases disseminated to the analysts and the investing public. Defendants Liautaud and 22 Tolonen signed the Q103, Q203 and Q303 Form 10-Qs. Defendants Liautaud and Tolonen signed 23 24 the FY03 Form 10-K. These financial statements and the statements about them were false and

25 misleading, as such financial information was not prepared in conformity with GAAP, nor was the

26 financial information a fair presentation of the Company’s operations due to the Company’s 27 improper accounting for its revenues and receivables, in violation of GAAP and SEC rules. 28

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1 Defendants manipulated Business Objects’ financial statements and failed to disclose its backlog of

2 unshipped orders. 3 73. GAAP are those principles recognized by the accounting profession as the 4 conventions, rules and procedures necessary to define accepted accounting practice at a particular 5 time. Regulation S-X (17 C.F.R. §210.4-01(a)(1)) states that financial statements filed with the SEC 6 which are not prepared in compliance with GAAP are presumed to be misleading and inaccurate. 7 8 Regulation S-X requires that interim financial statements must also comply with GAAP, with the

9 exception that interim financial statements need not include disclosure which would be duplicative

10 of disclosures accompanying annual financial statements. 17 C.F.R. §210.10-01(a). 11 74. Due to these accounting improprieties, the Company presented its financial results 12 and statements in a manner which violated GAAP, including the following fundamental accounting 13 principles: 14 15 (a) The principle that interim financial reporting should be based upon the same 16 accounting principles and practices used to prepare annual financial statements was violated

17 (Accounting Principles Board (“APB”) No. 28, ¶10);

18 (b) The principle that financial reporting should provide information that is useful 19 to present and potential investors and creditors and other users in making rational investment, credit 20 and similar decisions was violated (Financial Accounting Standards Board (“FASB”) Statement of 21 Concepts No. 1, ¶34); 22 23 (c) The principle that financial reporting should provide information about the 24 economic resources of an enterprise, the claims to those resources, and effects of transactions, events

25 and circumstances that change resources and claims to those resources was violated (FASB 26 Statement of Concepts No. 1, ¶40); 27 28

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1 (d) The principle that financial reporting should provide information about how

2 management of an enterprise has discharged its stewardship responsibility to owners (stockholders) 3 for the use of enterprise resources entrusted to it was violated. To the extent that management offers 4 securities of the enterprise to the public, it voluntarily accepts wider responsibilities for 5 accountability to prospective investors and to the public in general (FASB Statement of Concepts 6 No. 1, ¶50); 7 8 (e) The principle that financial reporting should provide information about an

9 enterprise’s financial performance during a period was violated. Investors and creditors often use

10 information about the past to help in assessing the prospects of an enterprise. Thus, although 11 investment and credit decisions reflect investors’ expectations about future enterprise performance, 12 those expectations are commonly based at least partly on evaluations of past enterprise performance 13 (FASB Statement of Concepts No. 1, ¶42); 14 15 (f) The principle that financial reporting should be reliable in that it represents 16 what it purports to represent was violated. That information should be reliable as well as relevant is

17 a notion that is central to accounting (FASB Statement of Concepts No. 2, ¶¶58-59);

18 (g) The principle of completeness, which means that nothing is left out of the 19 information that may be necessary to insure that it validly represents underlying events and 20 conditions was violated (FASB Statement of Concepts No. 2, ¶79); and 21 (h) The principle that conservatism be used as a prudent reaction to uncertainty to 22 23 try to ensure that uncertainties and risks inherent in business situations are adequately considered 24 was violated. The best way to avoid injury to investors is to try to ensure that what is reported

25 represents what it purports to represent (FASB Statement of Concepts No. 2, ¶¶95, 97). 26 75. Defendants also concealed from investors during the Class Period that: (1) the 27 Company improperly inflated its balance in deferred revenue due to manipulations in the deferred 28

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1 revenue balance of Crystal Decisions upon acquisition; and that (2) the demand for Business 2 Objects’ Enterprise 6 software was less than reported by the Company, and that the software was 3 unstable and potentially incompatible with other of the Company’s products.

4 ILLEGAL INSIDER SELLING 5 76. Notwithstanding his duty to refrain from selling stock or other securities while in 6 possession of material, adverse, non-public information concerning the Company, defendant 7 Liautaud sold $6.5 million worth of his shares at grossly inflated prices, thus benefiting from his 8 wrongful course of conduct. The complete insider trading data for Liautaud’s sales is attached 9 hereto as Ex. A.

10 FIRST CLAIM FOR RELIEF 11 For Violation of §10(b) of the 1934 Act and Rule 10b-5 Against All Defendants 12 77. Plaintiff incorporates ¶¶1-76 by reference. 13 78. During the Class Period, defendants disseminated or approved the false statements 14 specified above, which they knew or recklessly disregarded were materially false and misleading in 15 that they contained material misrepresentations and failed to disclose material facts necessary in 16 order to make the statements made, in light of the circumstances under which they were made, not 17 misleading. 18 79. Defendants violated §10(b) of the 1934 Act and Rule 10b-5 in that they: 19 (a) Employed devices, schemes and artifices to defraud; 20 (b) Made untrue statements of material facts or omitted to state material facts 21 22 necessary in order to make statements made, in light of the circumstances under which they were 23 made not misleading; or

24 (c) Engaged in acts, practices and a course of business that operated as a fraud or 25 deceit upon plaintiff and others similarly situated in connection with their purchases of Business 26 Objects publicly traded securities during the Class Period. 27 80. Plaintiff and the class have suffered damages in that, in reliance on the integrity of the 28 market, they paid artificially inflated prices for Business Objects publicly traded securities. Plaintiff

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1 and the class would not have purchased Business Objects publicly traded securities at the prices they 2 paid, or at all, if they had been aware that the market prices had been artificially and falsely inflated 3 by defendants’ misleading statements. 4 81. As a direct and proximate result of these defendants’ wrongful conduct, plaintiff and 5 the other members of the class suffered damages in connection with their purchases of Business 6 Objects publicly traded securities during the Class Period.

7 SECOND CLAIM FOR RELIEF 8 For Violation of §20(a) of the 1934 Act Against All Defendants 9 82. Plaintiff incorporates ¶¶1-81 by reference. 10 83. The Individual Defendants acted as controlling persons of Business Objects within 11 the meaning of §20(a) of the 1934 Act. By reason of their positions as officers and/or directors of 12 Business Objects, and their ownership of Business Objects stock, the Individual Defendants had the 13 power and authority to cause Business Objects to engage in the wrongful conduct complained of 14 herein. Business Objects controlled each of the Individual Defendants and each of its officers, 15 executives and all of its employees. By reason of such conduct, the Individual Defendants are liable 16 pursuant to §20(a) of the 1934 Act. 17 CLASS ACTION ALLEGATIONS 18 84. Plaintiff brings this action as a class action pursuant to Rule 23 of the Federal Rules 19 of Civil Procedure on behalf of all persons who purchased Business Objects publicly traded 20 securities on the open market during the Class Period. Excluded from the class are defendants, 21 directors and officers of Business Objects and their families and affiliates. 22 85. The members of the class are so numerous that joinder of all members is 23 impracticable. The disposition of their claims in a class action will provide substantial benefits to 24 the parties and the Court. During the Class Period, Business Objects had more than 89 million 25 shares of stock outstanding, owned by thousands of persons. 26 27 28

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1 86. There is a well-defined community of interest in the questions of law and fact 2 involved in this case. Questions of law and fact common to the members of the class which 3 predominate over questions which may affect individual class members include: 4 (a) Whether the 1934 Act was violated by defendants; 5 (b) Whether defendants omitted and/or misrepresented material facts; 6 (c) Whether defendants’ statements omitted material facts necessary to make the 7 statements made, in light of the circumstances under which they were made, not misleading; and 8 (d) Whether defendants knew or recklessly disregarded that their statements were 9 false and misleading. 10 87. Plaintiff’s claims are typical of those of the class because plaintiff and the class 11 sustained damages from defendants’ wrongful conduct. 12 88. Plaintiff will adequately protect the interests of the class and has retained counsel, 13 who are experienced in class action securities litigation. Plaintiff has no interests which conflict 14 with those of the class. 15 89. A class action is superior to other available methods for the fair and efficient 16 adjudication of this controversy.

17 SAFE HARBOR NOT APPLICABLE 18 90. The safe harbor does not apply to Business Objects’ false financial statements. The 19 defendants are liable for any false forward-looking statements pleaded because, at the time each was

20 made, the speaker knew that it was false and it was authorized or approved by a Business Objects 21 executive officer who knew that it was false. The safe harbor does not apply to the false statements 22 pleaded because they were not identified as forward-looking or because none of those pleaded 23 contained meaningful cautionary statements. None of the oral forward-looking statements in 24 Business Objects’ conference calls or other oral presentations pleaded were so identified as required 25 – nor were meaningful cautionary statements provided. None of the defendants’ historic or present- 26 tense statements was an assumption underlying or relating to any plan, projection or statement of 27 future economic performance, as they were not stated to be such when made nor were any of the 28 defendants’ projections or forecasts expressly related to or stated to be dependent on those historic or

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1 present-tense statements when made. None of the cautionary statements accompanying any of the 2 forward-looking statements alleged was meaningful because defendants had actual knowledge that 3 the statements were false when made and failed to disclose the known, existing, adverse, material 4 facts needed to make the forward-looking statements made not misleading

5 PRAYER 6 WHEREFORE, plaintiff prays for relief and judgment, including preliminary and permanent 7 injunctive relief, as follows: 8 A. Determining that this action is a proper class action, and certifying plaintiff as a class 9 representative under Rule 23 of the Federal Rules of Civil Procedure; 10 B. Awarding preliminary and permanent injunctive relief in favor of plaintiff and the 11 class against defendants and all persons acting under, in concert with, or for them, including an 12 accounting for and the imposition of a constructive trust and/or an asset freeze on defendants’ ill- 13 gotten gains; 14 C. Ordering an accounting of defendants’ ill-gotten gains; 15 D. Ordering disgorgement of defendants’ ill-gotten gains; 16 E. Awarding compensatory damages in favor of plaintiff and the other class members 17 against all defendants, jointly and severally, for all damages sustained as a result of defendants’ 18 wrongdoing, in an amount to be proven at trial, including interest thereon; 19 F. Awarding plaintiff and the class their reasonable costs and expenses incurred in this

20 action, including counsel fees and expert fees; and 21 G. Such other and further relief as the Court may deem just and proper.

22 JURY DEMAND 23 Plaintiff demands a trial by jury. 24 25 26 27 28

CONSOLIDATED COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS - C-04-2401-MJJ - 38 - Case 3:04-cv-02401-MJJ Document 25-1 Filed 01/07/2005 Page 40 of 42

1 DATED: January 7, 2005 LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 2 WILLIAM S. LERACH JONAH H. GOLDSTEIN 3 DAVID W. MITCHELL 4 5 /s/ Jonah H. Goldstein JONAH H. GOLDSTEIN 6 401 B Street, Suite 1600 7 San Diego, CA 92101 Telephone: 619/231-1058 8 619/231-7423 (fax) 9 Lead Counsel for Plaintiffs 10 S:\CasesSD\Business Objects\CPT00016859-a.doc 11 12 13 14 15 16 17 18 19

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CONSOLIDATED COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS - C-04-2401-MJJ - 39 - Case 3:04-cv-02401-MJJ Document 25-1 Filed 01/07/2005 Page 41 of 42

1 DECLARATION OF SERVICE BY MAIL 2 I, the undersigned, declare: 3 1. That declarant is and was, at all times herein mentioned, a citizen of the United States 4 and a resident of the County of San Diego, over the age of 18 years, and not a party to or interest in 5 the within action; that declarant’s business address is 401 B Street, Suite 1600, San Diego, California 6 92101.

7 2. That on January 7, 2005, declarant served the CONSOLIDATED COMPLAINT 8 FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS by depositing a true copy 9 thereof in a United States mailbox at San Diego, California in a sealed envelope with postage 10 thereon fully prepaid and addressed to the parties listed on the attached Service List. 11 3. That there is a regular communication by mail between the place of mailing and the 12 places so addressed. 13 I declare under penalty of perjury that the foregoing is true and correct. Executed this 7th 14 day of January, 2005, at San Diego, California. 15 /s/ Christine Clark 16 CHRISTINE CLARK 17 18 19

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C-04-2401-MJJ - 1 - EXHIBIT A

_T_ Business Objects Insider Sales 4/23/2003 to 2/20/2004

Name Date Shares Price Proceeds

Bernard Liautaud 5/5/2003 400 $ 23 .15 $ 9,260 .00 5/5/2003 400 $ 23 .12 $ 9,248 .00 5/5/2003 700 $ 23 .12 $ 16,184 .00 5/5/2003 400 $ 23 .11 $ 9,244 .00 5/5/2003 300 $ 23 .11 $ 6,933 .00 5/5/2003 900 $ 23 .10 $ 20,790.00 5/5/2003 200 $ 23 .10 $ 4,620.00 5/5/2003 300 $ 23 .09 $ 6,927.00 5/5/2003 600 $ 23 .09 $ 13,854.00 5/5/2003 1,000 $ 23 .08 $ 23,080.00 5/5/2003 800 $ 23 .07 $ 18,456.00 5/5/2003 600 $ 23 .07 $ 13,842.00 5/5/2003 500 $ 23 .06 $ 11, 530 .00 5/5/2003 800 $ 23 .06 $ 18,448.00 5/5/2003 300 $ 23 .06 $ 6,918.00 5/5/2003 2,700 $ 23 .05 $ 62,235.00 5/5/2003 600 $ 23 .05 $ 13,830.00 5/5/2003 200 $ 23 .05 $ 4,610.00 5/5/2003 300 $ 23 .04 $ 6,912.00 5/5/2003 800 $ 23 .04 $ 18,432.00 5/5/2003 1,200 $ 23 .03 $ 27,636.00 5/5/2003 1,200 $ 23 .02 $ 27,624.00 5/5/2003 500 $ 23.02 $ 11,510.00 5/5/2003 400 $ 23.02 $ 9,208.00 5/5/2003 300 $ 23.02 $ 6,906.00 5/5/2003 800 $ 23.01 $ 18,408.00 5/5/2003 300 $ 23.01 $ 6,903.00 5/5/2003 200 $ 23.01 $ 4,602.00 5/5/2003 600 $ 23.01 $ 13,806.00 5/5/2003 1,300 $ 23.00 $ 29,900.00 5/5/2003 1,100 $ 23.00 $ 25,300.00 5/5/2003 1,800 $ 23.00 $ 41,400.00 5/5/2003 1,600 $ 23.00 $ 36,800.00 5/5/2003 900 $ 22.99 $ 20,691 .00 5/5/2003 1,000 $ 22.99 $ 22,990.00 5/5/2003 100 $ 22.99 $ 2,299.00 5/5/2003 600 $ 22.98 $ 13,788.00 5/5/2003 400 $ 22.98 $ 9,192.00 5/5/2003 1,200 $ 22.97 $ 27,564.00 5/5/2003 600 $ 22.97 $ 13,782.00 5/5/2003 800 $ 22.96 $ 18,368.00 5/5/2003 1,200 $ 22.96 $ 27,552.00 5/5/2003 200 $ 22.96 $ 4,592.00 5/5/2003 400 $ 22.95 $ 9,180.00 5/5/2003 900 $ 22.95 $ 20,655.00 5/5/2003 200 $ 22.95 $ 4,590.00 5/5/2003 300 $ 22.94 $ 6,882 .00 5/5/2003 600 $ 22.94 $ 13,764.00 5/5/2003 800 $ 22 .93 $ 18,344 .00 5/5/2003 400 $ 22 .92 $ 9,168 .00 5/5/2003 200 $ 22 .91 $ 4,582.00 5/5/2003 600 $ 22 .91 $ 13,746 .00 5/5/2003 400 $ 22 .85 $ 9,140 .00 5/5/2003 200 $ 22 .78 $ 4,556 .00 5/5/2003 600 $ 22 .77 $ 13,662 .00 5/5/2003 1,600 $ 22 .72 $ 36,352 .00 5/5/2003 400 $ 22 .70 $ 9,080 .00 5/5/2003 400 $ 22 .69 $ 9,076 .00 5/5/2003 400 $ 22 .67 $ 9,068 .00 5/5/2003 400 $ 22 .64 $ 9,056 .00 5/5/2003 100 $ 22 .08 $ 2,208 .00 8/4/2003 600 $ 25.46 $ 15,276.00 8/4/2003 500 $ 25.44 $ 12,720 .00 8/4/2003 400 $ 25.42 $ 10,168 .00 8/4/2003 100 $ 25.32 $ 2,532 .00 8/4/2003 100 $ 25.31 $ 2,531 .00 8/4/2003 600 $ 25.94 $ 15,564.00 8/4/2003 200 $ 25.83 $ 5,166.00 8/4/2003 200 $ 25.82 $ 5,164.00 8/4/2003 400 $ 25.81 $ 10,324.00 8/4/2003 600 $ 25.80 $ 15,480.00 8/4/2003 800 $ 26.00 $ 20,800.00 8/4/2003 400 $ 25.99 $ 10,396.00 8/4/2003 800 $ 25 .97 $ 20,776.00 8/4/2003 800 $ 25.96 $ 20,768.00 8/4/2003 200 $ 25 .72 $ 5,144 .00 8/4/2003 200 $ 25 .68 $ 5,136 .00 8/4/2003 200 $ 25 .67 $ 5,134.00 8/4/2003 500 $ 25.61 $ 12,805.00 8/4/2003 500 $ 25.60 $ 12,800 .00 8/4/2003 600 $ 25 .56 $ 15,336 .00 8/4/2003 1,500 $ 25.54 $ 38,310 .00 8/4/2003 700 $ 25 .53 $ 17,871 .00 8/4/2003 600 $ 25.52 $ 15,312 .00 8/4/2003 300 $ 25.51 $ 7,653 .00 8/4/2003 2,200 $ 25.50 $ 56,100 .00 8/4/2003 400 $ 25.47 $ 10,188.00 8/4/2003 700 $ 25.46 $ 17,822 .00 8/4/2003 2,000 $ 25.45 $ 50,900.00 8/4/2003 600 $ 25.44 $ 15,264.00 8/4/2003 300 $ 25.42 $ 7,626.00 8/4/2003 600 $ 25.41 $ 15,246.00 8/4/2003 800 $ 25.40 $ 20,320.00 8/4/2003 200 $ 25.31 $ 5,062.00 8/4/2003 400 $ 25.25 $ 10,100.00 8/4/2003 400 $ 25.91 $ 10,364.00 8/4/2003 200 $ 25.90 $ 5,180.00 8/4/2003 400 $ 25.89 $ 10,356.00 8/4/2003 600 $ 25.88 $ 15,528.00 8/4/2003 400 $ 25.87 $ 10,348 .00 8/4/2003 400 $ 25.82 $ 10,328 .00 8/4/2003 500 $ 25.81 $ 12,905.00 8/4/2003 500 $ 25.80 $ 12,900 .00 8/4/2003 800 $ 25.76 $ 20,608 .00 8/4/2003 800 $ 25.75 $ 20,600.00 8/4/2003 400 $ 25.72 $ 10,288.00 8/4/2003 400 $ 25.71 $ 10,284.00 8/4/2003 800 $ 25.70 $ 20,560.00 8/4/2003 300 $ 25.68 $ 7,704.00 8/4/2003 100 $ 25.67 $ 2,567.00 8/4/2003 400 $ 25.66 $ 10,264.00 8/4/2003 800 $ 25.62 $ 20,496.00 8/4/2003 400 $ 25.61 $ 10,244.00 8/4/2003 600 $ 25.60 $ 15,360.00 8/4/2003 400 $ 25.59 $ 10,236.00 8/4/2003 400 $ 25.58 $ 10,232.00 8/4/2003 600 $ 25.57 $ 15,342.00 8/4/2003 100 $ 25.57 $ 2,557.00 8/4/2003 500 $ 25.56 $ 12,780.00 8/4/2003 1,600 $ 25 .55 $ 40,880.00 8/4/2003 1,300 $ 25.54 $ 33,202 .00 8/4/2003 800 $ 25.53 $ 20,424.00 8/4/2003 700 $ 25.52 $ 17,864 .00 8/4/2003 500 $ 25.51 $ 12,755 .00 8/4/2003 1,600 $ 25.48 $ 40,768 .00 8/4/2003 400 $ 25.95 $ 10,380 .00 8/4/2003 200 $ 25.94 $ 5,188 .00 8/4/2003 800 $ 26.03 $ 20,824.00 8/4/2003 400 $ 25.93 $ 10,372 .00 8/4/2003 300 $ 25.47 $ 7,641 .00 8/4/2003 200 $ 25.73 $ 5,146.00 11/3/2003 200 $ 34.01 $ 6,801 .00 11/3/2003 200 $ 33.87 $ 6,774.00 11/3/2003 200 $ 33.94 $ 6,787.00 11/3/2003 105 $ 34.02 $ 3,572.25 11/3/2003 600 $ 33.91 $ 20,346.00 11/3/2003 300 $ 33.82 $ 10,146.00 11/3/2003 700 $ 33.90 $ 23,730.00 11/3/2003 200 $ 34.00 $ 6,800.00 11/3/2003 182 $ 33.97 $ 6,182.54 11/3/2003 100 $ 33.93 $ 3,393.00 11/3/2003 300 $ 33 .92 $ 10,176.00 11/3/2003 300 $ 33.86 $ 10,158.00 11/3/2003 100 $ 33 .85 $ 3,385.00 11/3/2003 100 $ 33 .99 $ 3,399 .00 11/3/2003 100 $ 34 .02 $ 3,402 .00 11/3/2003 200 $ 34 .03 $ 6,805.00 11/3/2003 600 $ 33 .95 $ 20,370.00 11/3/2003 200 $ 33 .85 $ 6,769 .00 11/3/2003 200 $ 33 .89 $ 6,778 .00 11/3/2003 200 $ 33 .84 $ 6,768 .00 11/3/2003 200 $ 34 .00 $ 6,799.00 11/3/2003 200 $ 33.90 $ 6,779.00 11/3/2003 900 $ 33 .67 $ 30,303.00 11/3/2003 100 $ 33 .78 $ 3,378 .00 11/3/2003 100 $ 33.76 $ 3,376.00 11/3/2003 500 $ 33.60 $ 16,800 .00 11/3/2003 400 $ 33 .57 $ 13,428 .00 11/3/2003 500 $ 33.80 $ 16,900 .00 11/3/2003 100 $ 33.58 $ 3,358 .00 11/3/2003 200 $ 33.59 $ 6,717 .00 11/3/2003 400 $ 33.70 $ 13,480 .00 11/3/2003 600 $ 33.59 $ 20,154.00 11/3/2003 200 $ 33.64 $ 6,728 .00 11/3/2003 400 $ 33.79 $ 13,516.00 11/3/2003 300 $ 33.57 $ 10,071 .99 11/3/2003 1,300 $ 33.66 $ 43,758.00 11/3/2003 200 $ 33.69 $ 6,738.00 11/3/2003 100 $ 33.61 $ 3,361 .00 11/3/2003 700 $ 33.63 $ 23,541 .00 11/3/2003 118 $ 33.56 $ 3,960.08 11/3/2003 100 $ 33.68 $ 3,368.00 11/3/2003 200 $ 33.72 $ 6,743.00 11/3/2003 400 $ 33.73 $ 13,492.00 11/3/2003 200 $ 33.71 $ 6,742.00 11/3/2003 300 $ 33.62 $ 10,086.00 11/3/2003 800 $ 33.72 $ 26,976.00 11/3/2003 700 $ 33.74 $ 23,618.00 11/3/2003 200 $ 33 .77 $ 6,754 .00 11/3/2003 200 $ 33.65 $ 6,729.00 11/3/2003 200 $ 33 .70 $ 6,739 .00 11/3/2003 300 $ 33 .71 $ 10,112 .01 11/3/2003 2,600 $ 33 .65 $ 87,490 .00 11/3/2003 300 $ 33.63 $ 10,089 .00 11/3/2003 350 $ 33 .53 $ 11,735 .50 11/3/2003 300 $ 33.73 $ 10,118 .01 11/3/2003 900 $ 33.67 $ 30,303.00 11/3/2003 400 $ 33.59 $ 13,434 .00 11/3/2003 200 $ 33.72 $ 6,743.00 11/3/2003 300 $ 33.59 $ 10,077.00 11/3/2003 200 $ 33.69 $ 6,737.00 11/3/2003 100 $ 33.72 $ 3,372.00 11/3/2003 100 $ 33.58 $ 3,358.40 11/3/2003 200 $ 33.56 $ 6,712.00 11/3/2003 350 $ 33.64 $ 11, 774 .00 11/3/2003 900 $ 33.66 $ 30,294.00 11/3/2003 300 $ 33.74 $ 10,122.99 11/3/2003 600 $ 33.71 $ 20,227.98 11/3/2003 600 $ 33.70 $ 20,220.00 11/3/2003 200 $ 33.50 $ 6,699.00 11/3/2003 500 $ 33.60 $ 16,800.00 11/3/2003 700 $ 33.73 $ 23,611 .00 11/3/2003 2,700 $ 33.65 $ 90,855.00 11/3/2003 300 $ 33.57 $ 10,071 .00 11/3/2003 200 $ 33.47 $ 6,693 .00 11/3/2003 200 $ 33.58 $ 6,716 .00 11/3/2003 400 $ 33.65 $ 13,459 .00 11/3/2003 100 $ 33.56 $ 3,356 .1 0 11/3/2003 500 $ 33.69 $ 16,845.00 11/3/2003 100 $ 33.68 $ 3,368.00 11/3/2003 200 $ 33.47 $ 6,694 .00 11/3/2003 500 $ 33.62 $ 16,810.00 11/3/2003 300 $ 33.49 $ 10,047.99 11/3/2003 400 $ 34.04 $ 13,614.00 11/3/2003 800 $ 33.95 $ 27,160.00 11/3/2003 400 $ 33.92 $ 13,568.00 11/3/2003 200 $ 33.87 $ 6,774.00 11/3/2003 100 $ 33.83 $ 3,383.00 11/3/2003 500 $ 33.80 $ 16,900.00 11/3/2003 200 $ 34.00 $ 6,800.00 11/3/2003 100 $ 33.44 $ 3,344.00 11/3/2003 200 $ 33.86 $ 6,772.00 11/3/2003 100 $ 33.44 $ 3,344.00 11/3/2003 200 $ 33 .86 $ 6,772.00 11/3/2003 300 $ 33.76 $ 10,128.00 11/3/2003 100 $ 33 .93 $ 3,393.00 11/3/2003 200 $ 33.84 $ 6,768.00 11/3/2003 300 $ 33 .79 $ 10,137 .00 11/3/2003 100 $ 33 .91 $ 3,391 .00 11/3/2003 395 $ 33.53 $ 13,244 .35 11/3/2003 300 $ 33.86 $ 10,158 .99 11/3/2003 200 $ 33 .99 $ 6,798 .00 11/3/2003 300 $ 33.90 $ 10,170 .00 11/3/2003 400 $ 33.90 $ 13,558 .00 11/3/2003 200 $ 33.78 $ 6,756 .00 11/3/2003 200 $ 34.00 $ 6,799.00 11/3/2003 200 $ 33.75 $ 6,749 .00 11/3/2003 300 $ 33.86 $ 10,157.01 11/3/2003 300 $ 33.49 $ 10,047.99 11/3/2003 400 $ 33.88 $ 13,552.00 11/3/2003 200 $ 33.50 $ 6,699.00 11/3/2003 400 $ 33.94 $ 13,574.00 11/3/2003 200 $ 33.95 $ 6,789.00 11/3/2003 100 $ 33.77 $ 3,377.00 2/20/2004 12,400 $ 32.49 $ 402,876 .00 2/20/2004 11,200 $ 32.47 $ 363,664 .00 2/20/2004 2,100 $ 32.47 $ 68,187.00 2/20/2004 300 $ 32.46 $ 9,738.00 2/20/2004 4,800 $ 32.45 $ 155,760.00 2/20/2004 7,700 $ 32 .43 $ 249,711 .00 2/20/2004 3,100 $ 32 .35 $ 100,285 .00 2/20/2004 600 $ 32.21 $ 19,326.00 2/20/2004 100 $ 32 .20 $ 3,220.00 2/20/2004 600 $ 32 .19 $ 19,314.00 2/20/2004 4,500 $ 32 .17 $ 144,765 .00 2/20/2004 1,900 $ 32.16 $ 61,104.00 2/20/2004 200 $ 32.16 $ 6,432.00 2/20/2004 500 $ 32.15 $ 16,075.00 2/20/2004 12,600 $ 32.49 $ 409,374.00 2/20/2004 10,500 $ 32.47 $ 340,935 .00 2/20/2004 1,900 $ 32.49 $ 61,731 .00 2/20/2004 5,200 $ 32.45 $ 168,740 .00 2/20/2004 7,300 $ 32.43 $ 236,739.00 2/20/2004 2,900 $ 32.35 $ 93,815.00 2/20/2004 400 $ 32.21 $ 12,884.00 2/20/2004 300 $ 32.20 $ 9,660.00 2/20/2004 400 $ 32.19 $ 12,876.00 2/20/2004 900 $ 32.17 $ 28,953.00 2/20/2004 3,300 $ 32.17 $ 106,161 .00 2/20/2004 2,600 $ 32.16 $ 83,616.00 2/20/2004 1,100 $ 32.15 $ 35,365.00 2/20/2004 600 $ 32.15 $ 19,290.00 220,100 $ 6,537,705.18 BUSINESS OBJECTS (N .D. Cal .) (LEAD) Service List - 1/7/2005 (04-0181) Pane 1 of 1 Counsel For Defendant(s) Claudia N. Main Boris Feldman Wilson Sonsini Goodrich & Rosati, P .C. Douglas J . Clark One Market Street, Spear Tower, Suite 3300 Peri B. Nielsen San Francisco, CA 9410 5 Wilson Sonsini Goodrich & Rosati, P .C. 415/947-2000 650 Page Mill Roa d 415/947-2099(Fax ) Palo Alto, CA 94304-1050 650/493-9300 650/493-6811 (Fax)

Counsel For Plaintiff(s) William S. Lerach Michael J . Vanoverbeke Jonah H. Goldstein Thomas C . Michaud Valerie L. McLaughlin Michael E . Moco Lerach Coughlin Stoia Geller Rudman & Vanoverbeke Michaud & Timmony, P .C. Robbins LL P 79 Alfred Street 401 B Street, Suite 1600 Detroit, MI 48201 San Diego, CA 92101-4297 313/578-1200 619/231-1058 313/578-1201 (Fax) 619/231-7423(Fax)