1 ROBBINS GELLER RUDMAN & DOWD LLP 2 SHAWN A. WILLIAMS (213113) Post Montgomery Center 3 One Montgomery Street, Suite 1800 San Francisco, CA 94104 4 Telephone: 415/288-4545 415/288-4534 (fax) 5
[email protected] – and – 6 SAMUEL H. RUDMAN MARY K. BLASY (211262) 7 58 South Service Road, Suite 200 Melville, NY 11747 8 Telephone: 631/367-7100 9 631/367-1173 (fax)
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[email protected] 11 Attorneys for Plaintiff 12 [Additional counsel appear on signature page.] 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 RYAN KELLY, Individually and on Behalf of ) Case No. All Others Similarly Situated, ) 16 ) CLASS ACTION Plaintiff, ) 17 ) COMPLAINT FOR VIOLATIONS OF THE vs. ) FEDERAL SECURITIES LAWS 18 ) ELECTRONIC ARTS, INC., ANDREW ) 19 WILSON, BLAKE JORGENSEN, PATRICK ) SÖDERLUND, FRANK D. GIBEAU and ) 20 PETER ROBERT MOORE, ) ) 21 Defendants. ) ) DEMAND FOR JURY TRIAL 22 23 24 25 26 27 28 1 Plaintiff, Ryan Kelly (“plaintiff”), individually and on behalf of all others similarly situated, 2 by plaintiff’s undersigned attorneys, for plaintiff’s complaint against defendants, alleges the 3 following based upon personal knowledge as to plaintiff and plaintiff’s own acts, and upon 4 information and belief as to all other matters based on the investigation conducted by and through 5 plaintiff’s attorneys, which included, among other things, a review of Securities and Exchange 6 Commission (“SEC”) filings by Electronic Arts, Inc. (“Electronic Arts,” “EA” or the “Company”), 7 as well as media and analyst reports about the Company and conference call transcripts. Plaintiff 8 believes that substantial additional evidentiary support will exist for the allegations set forth herein 9 after a reasonable opportunity for discovery.