1 LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 2 PATRICK J. COUGHLIN (111070) 100 Pine Street, Suite 2600 3 San Francisco, CA 94111 Telephone: 415/288-4545 4 415/288-4534 (fax) – and – 5 WILLIAM S. LERACH (68581) DARREN J. ROBBINS (168593) 6 401 B Street, Suite 1600 San Diego, CA 92101 7 Telephone: 619/231-1058 619/231-7423 (fax) 8 Attorneys for Plaintiff 9

10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 DANIEL SWANTKO, On Behalf of Himself ) No. 13 and All Others Similarly Situated, ) ) CLASS ACTION 14 Plaintiff, ) ) COMPLAINT FOR VIOLATION OF THE 15 vs. ) FEDERAL SECURITIES LAWS ) 16 , INC., BRUCE ) McMILLAN, JOEL LINZNER, LAWRENCE ) 17 F. PROBST, III, GERHARD FLORIN, ) WARREN C. JENSON, DON A. MATTRICK, ) 18 NANCY L. SMITH and J. RUSSELL RUEFF, ) JR., ) 19 ) Defendants. ) 20 ) DEMAND FOR JURY TRIAL

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1 INTRODUCTION 2 1. This is a securities class action on behalf of purchasers of the publicly traded 3 securities of Electronic Arts, Inc. (“Electronic Arts” or the “Company”) between December 6, 2004 4 and March 21, 2005 (the “Class Period”), against Electronic Arts and certain of its officers and 5 directors for violations of the Securities Exchange Act of 1934 (the “1934 Act”). 6 2. During the Class Period, defendants made false and misleading statements about 7 Electronic Arts’ business and prospects. As a result of the defendants’ false statements, Electronic 8 Arts stock traded at inflated levels during the Class Period, increasing to as high as $69.46 on March 9 9, 2005, allowing the Company’s top officers and directors to sell more than $56 million worth of 10 their own shares at inflated prices. 11 3. On March 21, 2005, Electronic Arts announced “revised estimates for the Company’s 12 fiscal year ending March 31, 2005,” stating that the “changes are primarily the result of lower than 13 expected sales in both North America and Europe.” For its year ending March 31, 2005, Electronic 14 Arts revealed that it now expected earnings per share (“EPS”) between $1.62 and $1.64 a share, 15 badly missing its prior guidance of $1.82 to $1.87 a share. The Company’s revenue projections were 16 also reversed and lowered to between $3.100 billion and $3.125 billion, from $3.275 billion and 17 $3.325 billion. 18 4. The dramatic reductions in the Company’s projections shocked the investment 19 community, but were of no surprise to defendants. In fact, defendants realized as early as 20 December 2004 the long-term nature of the hardware shortages which would have a deleterious 21 effect on the Company’s game sales until the next-generation models were finally released. 22 Defendants knew this would severely impact their sales – without the game consoles, consumers 23 have no incentive to buy the games. 24 5. In response to revelations of the Company’s misleading projections and questionable 25 explanation for the Company’s various quarterly failures, the Company’s shares were pummeled by 26 a massive wave of selling which exceeded 39 million shares in a single day. Public investors 27 incurred hundreds of millions in losses as a result of defendants’ scheme to line their own pockets. 28 On March 22, 2005, shares of the Company fell $11.20 per share, to close at $55.15 per share.

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1 6. The true facts, which were known by each of the defendants but concealed from the 2 investing public during the Class Period, were as follows: 3 (a) The Company was experiencing a dramatic adverse trend in the Company’s 4 sales of its holiday releases; 5 (b) The Company’s internal sales reports were revealing that contrary to growth, 6 the Company was actually experiencing year over year decline in revenue and market share in the 7 Company’s Q4 2005 (this followed similar results in Q3 2005); 8 (c) Due to a lack of game consoles (which were necessary for utilizing 9 defendants’ products) defendants knew that consumer demand would dramatically deteriorate while 10 the Company’s public forecasting actually called for increasing sales growth; and 11 (d) As a result of (a)–(c) above, the Company’s claim of achieving Q4 2005 EPS 12 growth reaching $1.82-$1.87 per share was materially overstated. 13 JURISDICTION AND VENUE 14 7. Jurisdiction is conferred by §27 of the 1934 Act. The claims asserted herein arise 15 under §§10(b) and 20(a) of the 1934 Act and Rule 10b-5. 16 8. Venue is proper in this District pursuant to §27 of the 1934 Act. Many of the false 17 and misleading statements were made in or issued from this District. 18 9. The Company’s principal executive offices are in Redwood City, California, where 19 the day-to-day operations of the Company are directed and managed. 20 THE PARTIES 21 10. Plaintiff Daniel Swantko purchased Electronic Arts publicly traded securities as 22 described in the attached certification and was damaged thereby. 23 11. Defendant Electronic Arts develops, markets, publishes and distributes interactive 24 software games that are payable by consumers. 25 12. Defendant Bruce McMillan (“McMillan”) is Executive Vice President, Worldwide 26 Studios, of Electronic Arts. During the Class Period, McMillan sold more than $8.1 million worth of 27 his Electronic Arts stock. 28

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1 13. Defendant Joel Linzner (“Linzner”) is Senior Vice President of Business & Legal 2 Affairs of Electronic Arts. During the Class Period, Linzner sold more than $1.7 million worth of 3 his Electronic Arts stock. 4 14. Defendant Lawrence F. Probst, III (“Probst”) is Chairman and Chief Executive 5 Officer of Electronic Arts. During the Class Period, Probst sold more than $6.3 million worth of his 6 Electronic Arts stock. 7 15. Defendant Gerhard Florin (“Florin”) is Senior Vice President and Managing Director, 8 European Publishing, of Electronic Arts. During the Class Period, Florin sold more than 9 $3.8 million worth of his Electronic Arts stock. 10 16. Defendant Warren C. Jenson (“Jenson”) is Chief Financial Officer and Chief 11 Administrative Officer of Electronic Arts. During the Class Period, Jenson sold more than 12 $12.5 million worth of his Electronic Arts stock. 13 17. Defendant Don A. Mattrick (“Mattrick”) is President, Worldwide Studios, of 14 Electronic Arts. During the Class Period, Mattrick sold more than $17 million worth of his 15 Electronic Arts stock. 16 18. Defendant Nancy L. Smith (“Smith”) is Executive Vice President of Electronic Arts. 17 During the Class Period, Smith sold more than $4.2 million worth of her Electronic Arts stock. 18 19. Defendant J. Russell Rueff, Jr. (“Rueff”) is Executive Vice President, Human 19 Resources, of Electronic Arts. During the Class Period, Rueff sold more than $2.5 million worth of 20 his Electronic Arts stock. 21 20. The individuals named as defendants in ¶¶12-19 are referred to herein as the 22 “Individual Defendants.” The Individual Defendants, because of their positions with the Company, 23 possessed the power and authority to control the contents of Electronic Arts’ quarterly reports, press 24 releases and presentations to securities analysts, money and portfolio managers and institutional 25 investors, i.e., the market. Each defendant was provided with copies of the Company’s reports and 26 press releases alleged herein to be misleading prior to or shortly after their issuance and had the 27 ability and opportunity to prevent their issuance or cause them to be corrected. Because of their 28 positions and access to material non-public information available to them but not to the public, each

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1 of these defendants knew that the adverse facts specified herein had not been disclosed to and were 2 being concealed from the public and that the positive representations being made were then 3 materially false and misleading. The Individual Defendants are liable for the false statements 4 pleaded herein at ¶42, as those statements were “group-published” information, the result of the 5 collective actions of the Individual Defendants. 6 SCIENTER 7 21. In addition to the above-described involvement, each Individual Defendant had 8 knowledge of Electronic Arts’ problems and was motivated to conceal such problems and each 9 reaped millions of dollars in insider trading proceeds – all transpiring in just a few days. During this 10 brief window of time, each defendant was able to individually trump their own salary by insider 11 trading. Although their salary would require defendants to wade through 365 days of fulfilling their 12 official duties, defendants in just minutes (individually) were able to realize millions of dollars above 13 and beyond their salaries. Probst, Linzner, Jenson and Mattrick, as Chairman/CEO, Vice President 14 of Legal Affairs, CFO/CAO and President, respectively, were responsible for financial reporting 15 and/or communications with the market. Many of the internal reports showing Electronic Arts’ 16 forecasted and actual growth were prepared by the finance department, with input from Linzner, 17 Jenson and Mattrick, all of which would impact the financial results and press releases issued by the 18 Company or results associated with their own individual departments. Each Individual Defendant 19 sought to demonstrate that he/she could lead the Company successfully and generate the growth 20 expected by the market for Q4 2005 and FY 2005. 21 FRAUDULENT SCHEME AND COURSE OF BUSINESS 22 22. Each defendant is liable for (i) making false statements, or (ii) failing to disclose 23 adverse facts known to him/her about Electronic Arts. Defendants’ fraudulent scheme and course of 24 business that operated as a fraud or deceit on purchasers of Electronic Arts publicly traded securities 25 was a success, as it (i) deceived the investing public regarding Electronic Arts’ prospects and 26 business; (ii) artificially inflated the prices of Electronic Arts’ publicly traded securities; (iii) allowed 27 defendants to arrange to sell and actually sell in excess of $56 million worth of Electronic Arts 28

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1 shares at artificially inflated prices; and (iv) caused plaintiff and other members of the Class to 2 purchase Electronic Arts publicly traded securities at inflated prices. 3 BACKGROUND AND OVERVIEW OF SCHEME 4 23. Electronic Arts develops, markets, publishes and distributes interactive software 5 games that are playable on the following platforms: 6 (a) Home videogame machines such as the Sony PlayStation 2 (“PS2”), 7 Microsoft (“Xbox”), Nintendo GameCubeTM and Sony PlayStation consoles; 8 (b) Personal computers (“PCs”); 9 (c) Hand-held game machines such as the Game Boy Advance and Sony’s 10 PlayStation Portable (“PSP”); and 11 (d) Online, over the Internet and other proprietary online networks. 12 24. During fiscal 2004, the Company published 32 new internally developed titles and co- 13 published an additional 11 new titles. The Company publishes products in a number of categories 14 such as sports, action, strategy, simulations, role playing and adventure, with its sports-related 15 products, marketed under the EA SPORTS brand name, accounting for a significant percentage of 16 net revenue in each of fiscal years 2004, 2003 and 2002. Electronic Arts’ currently biggest selling 17 games are:

18 · Madden NFL 2004 (professional football) 19 · NCAA® Football 2004 (collegiate football) 20 · FIFA Soccer 2004 (professional soccer) 21 · NBA Live 2004 (professional basketball) 22 · NHL 2004 (professional hockey) 23 · MVP Baseball TM 2004 (professional baseball) 24 · NASCAR ThunderTM 2004 (stock car racing) 25 · The Lord of the Rings; The Return of the King 26 · James Bond 007: Everything or Nothing 27 · Bustin’ Out 28 · Underground

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1 · Medal of Honor Rising Sun 2 · NFL STREET (football) 3 · SSX 3 (snowboarding) 4 · Def Jam VENDETTA (wrestling) 5 · NBA STREET Vol. 2 (basketball) 6 25. The Company pays a fee to console manufacturers (the so-called “hardware”) for the 7 right to publish products on their platforms. As of June 2004, the Company had published titles 8 which could be played on 43 consoles since its inception, but the majority of its titles are sold to be 9 played on just three consoles: 10 (a) PlayStation 2. Sony released the PlayStation 2 console in Japan in 11 March 2000, in North America in October 2000, and in Europe in November 2000. The 12 PlayStation 2 console is a 128-bit, DVD-based system that, with a network adaptor, is Internet ready, 13 as well as backward compatible with games published for its predecessor, the PlayStation. 14 (b) Nintendo GameCube. Nintendo launched the Nintendo GameCube console 15 in Japan in September 2001, North America in November 2001 and Europe in May 2002. The 16 Nintendo GameCube plays games that are manufactured on a proprietary optical disk. 17 (c) Xbox. Microsoft launched the Xbox console in North America in 18 November 2001, in Japan in February 2002 and in Europe in March 2002. The Microsoft Xbox is a 19 128-bit, DVD-based system that is Internet ready. 20 26. While Electronic Arts is the largest game designer which develops and publishes 21 software games licensed to operate on console platforms sold by other companies, it also competes 22 against hardware designers Sony, Microsoft and Nintendo, each of which develops and publishes 23 their own software for their respective console platforms. 24 27. The retail selling prices of Electronic Arts’ newly released products in North America 25 (excluding re-releases of older titles marketed as “Classics”), typically ranges from $30.00 to $50.00. 26 “Classics” titles have retail selling prices that range from $10.00 to $20.00. 27 28. In fiscal 2004, approximately 44% of the Company’s net revenue was derived from 28 sales of EA Studio software for the PlayStation 2, compared to 37% in fiscal 2003. The Company

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1 released 24 titles worldwide in fiscal 2004 for the PlayStation 2, compared to 19 titles in fiscal 2003. 2 Its top five PlayStation 2 releases for the year were Need for Speed Underground, Madden NFL 3 2004, Medal of Honor Rising Sun, The Lord of the Rings; The Return of the King and FIFA Soccer 4 2004. PlayStation product sales decreased in fiscal 2004 primarily due to the transition to Sony’s 5 new PS2 console platform. Although PlayStation products can be played on the PS2 console, 6 PlayStation product sales continued to decline in fiscal 2005 which began on April 1, 2004. 7 29. During fiscal 2004, approximately 13% of the Company’s net revenue was derived 8 from sales of EA Studio software for the Xbox, compared to 9% in fiscal 2003. The Company 9 released 21 titles worldwide in fiscal 2004 for the Xbox, compared to 16 titles in fiscal 2003. Its top 10 five Xbox releases for fiscal 2003 were also Need for Speed Underground, Madden NFL 2004, 11 Medal of Honor Rising Sun, The Lord of the Rings; The Return of the King and FIFA Soccer 2004. 12 30. During fiscal 2004, approximately 7% of Electronic Arts’ net revenue was derived 13 from sales of EA Studio software for the Nintendo GameCube, compared to 7% in fiscal 2003. The 14 Company released 19 titles worldwide in fiscal 2004 for the Nintendo GameCube, compared to 17 15 titles in fiscal 2003. Its top five Nintendo GameCube releases for the year were Need for Speed 16 Underground, The Lord of the Rings; The Return of the King, Medal of Honor Rising Sun, Madden 17 NFL 2004 and James Bond 007: Everything or Nothing. 18 31. During the 2004 holiday sales season, the game industry began going through a 19 familiar and potentially detrimental console transition cycle. During these cycles, the major game 20 machine manufacturers – Sony, Microsoft, and Nintendo – unveil their next-generation consoles 21 which have the potential of creating significant hardware gluts as consumers reject the older 22 hardware models and hold out to purchase the newer hardware models. Once the newer models are 23 announced, it is well known in the industry that manufacturers and retailers alike avoid taking on 24 significant inventories of the soon-to-be out-of-date older version hardware. Sony, Microsoft and 25 Nintendo were each scheduled to unveil their next-generation consoles in May 2005, with Nintendo 26 starting to sell them as early as the fall of 2005, followed by Sony’s PlayStation 3 and Microsoft’s 27 Xbox 2 in 2006. 28

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1 32. During previous console transitions, the publishers, including Electronic 2 Arts, also saw revenue slow or slump as prices declined for games on the older consoles, and costs 3 skyrocketed as they developed titles for the new machines. As calendar year 2004 drew to an end, 4 Electronic Arts feared it would face similar troubles as the console cycle came to a close. 5 33. Predictably, as the 2004 holiday season drew to an end, game hardware suppliers 6 began to cut the prices of their consoles to $150, causing sales of consoles to spiral, leading to 7 massive shortages of consoles at retailers. With Microsoft, Sony and Nintendo set to launch their 8 new models, there was no incentive to build the older models. Along with those consoles, 9 consumers were purchasing a lot of games – just not Electronic Arts’ titles. Competitor Take-Two 10 Interactive Software, with its Grand Theft Auto franchise, reported net income increases of 74% for 11 its last quarter year over year. Net income at competitor was also up 26% during its last 12 quarter. Sales were so good at competitor THQ that the company raised earnings guidance. Leading 13 game retailer GameStop was also reporting record sales. 14 34. Meanwhile, sales of Electronic Arts’ titles had flattened and in some instances were 15 crashing. Throughout the Class Period, defendants were receiving daily reports of plummeting sales 16 figures for the Company’s top selling titles while the industry as a whole was increasing sales as a 17 result of the price slashes on the old hardware systems. 18 35. Electronic Arts’ insiders were sitting on tens of millions of dollars worth of stock 19 options they intended to cash in. Electronic Arts’ insiders were caught in a catch-22 though: if they 20 openly acknowledged the damning effect their internal forecasting demonstrated the console 21 shortages would continue to have on the Company’s profitability through the fall of 2005 and early 22 spring 2006 when the new consoles were released, the market would panic and the Company’s stock 23 price would fall. Stock options are only valuable when the strike price is sufficiently lower than the 24 stock price. Hence, revelations that Electronic Arts’ game sales would not meet Wall Street’s 25 expectations if the console shortage continued would devalue the stock options because the 26 Company’s stock price would fall. 27 36. Thus, defendants concocted charades to allay the market’s fears. First, Electronic 28 Arts, which did not itself sell hardware, but was the largest non-hardware producing game retailer,

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1 downplayed the expected duration of the console shortage. Though defendants knew as a result of 2 their internal development forecasting where Sony, Microsoft and Nintendo were at with their next- 3 generation console development, defendants assured the market that the console shortages were 4 temporary and consoles would be readily available by Christmas or by “January or February or 5 March” of 2005 at the latest. 6 37. But more importantly, defendants made inflated sales and earnings forecasts knowing 7 that their own internal forecasts showed significantly lower sales and earnings. Defendants 8 concealed from the market that their public forecasts did not account for a continued console 9 shortage and instead were based on fictional “catch-up” sales of software that would never 10 materialize as the hardware shortage continued. Defendants also concealed and misstated the 11 effect of pricing-pressure its competitors’ price slashing was having on its own internal sales and 12 earning projections. 13 38. Finally, despite receiving daily sales reports demonstrating the Company’s 14 diminishing software sales, defendants continued to assure the market that its games were selling as 15 well as, if not better than the rest of the market’s. 16 DEFENDANTS’ FALSE AND MISLEADING STATEMENTS ISSUED DURING THE CLASS PERIOD 17 39. On December 6, 2004, Electronic Arts Chairman and Chief Executive Officer 18 Lawrence Probst (“Probst”) appeared at the 32nd Annual USB Annual Media Conference. Probst’s 19 statements included: 20 Transition is our friend at Electronic Arts. 21 * * * 22 As the quality gets better, we think that also helps us appeal to a broader 23 demographic so that we can continue to expand the business and grow top line and bottom line. 24 * * * 25 I know Sony is doing everything in their power to supply the market w[ith] as much 26 hardware as they can to meet consumer demand but that’s a question mark as we go between now and the end of the month of December. 27 * * * 28

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1 I will tell you that we monitor channel sell-through on a daily basis with all of our key customers and we are very closely monitoring sales on our key sports titles, 2 whether it was “Madden Football” or “NBA Live” as well as the competition’s product at $19.95. And we were not happy with the trends that we were seeing and 3 as a consequence we built a couple of models, one at a $39.95 price point, one at a $29.95 price point, one at a $19.95 price point and elected to adopt the $29.95 4 pricing strategy and I will tell you that in retrospect it was exactly the right thing to do. We have exceeded our internal model in terms of what we expected to see in 5 terms of increased unit sales and so we are very happy with the decision. What does that mean for next year? 6 I think that you’ll see us, once again, bring our titles to market a premium 7 price point. I don’t know what that’ll be next year but it’ll be in line with other premium priced titles. And I think you may see some changes from the competition 8 because the licensors like the leagues and player associations I think will implement minimum unit royalties, not only for the people that have employed a $19.95 pricing 9 strategy, but I think for everybody in the industry that may be a licensee and so I think that will make it very difficult to have a successful financial model in the future 10 at a $19.95 price point. So I think you are going to see an adjustment there. And you are going to see us continue to price our products at a premium level. 11 * * * 12 I think you’re going to see Sony bend over backwards to try to catch up to the 13 demand as much as possible over the next two to three weeks. I am sure they are manufacturing as quickly as they can and shipping these things as quickly as they 14 can. But this is a short term blip and if they don’t supply all the consumer demand between now and December 25th, they will catch up in January or February or 15 March.” 16 40. Again, on December 7, 2004, Probst appeared at the Credit Suisse First Boston Media 17 Week conference. As he had at the UBS conference, Probst opened discussing “some of the key 18 characteristics of our company which we think makes Electronic Arts a very compelling investment 19 opportunity and those would include, number one, EA’s a digital entertainment pure play with long 20 term growth drivers. Number two, we’re a leader and we’re playing from a position of strength, and 21 number three, we have a track record of success with strong performance characteristics.” Again, 22 Probst assured that he knew Sony was “doing everything they c[ould] to supply the consumer 23 demand . . . but the inventories are a little short on the Playstation 2 at the moment.” 24 41. On these positive statements, the Company’s stock price, which opened at $52.47 on 25 the morning of December 6, 2004, climbed to close at over $60 per share by December 14, 2004. 26 42. On January 25, 2005, the Company issued a press release entitled “Electronic Arts 27 Reports Fiscal Third Quarter Results; Long-Term Exclusives with NFL and ESPN; Record Cash 28 Flows for Last 12 Months.” The press release stated in part:

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1 Fiscal Year Expectations – Ending March 31, 2005

2 · Net revenue is expected to be between $3.275 and $3.325 billion – as compared to $2.957 billion for fiscal 2004. 3 · Non-GAAP diluted earnings per share are expected to be between $1.90 4 and $1.95 – as compared to $1.84 for fiscal 2004. This range does not factor in eight cents of estimated charges related principally to our 5 acquisition of Criterion Software and tender offer for Digital Illusions C.E.

6 · GAAP diluted earnings per share are expected to be between $1.82 and $1.87 – as compared to $1.87 for fiscal 2004.1 7 Our expected results include the projected impact of our share repurchase 8 program. 9 43. The FY 2005 projections, extrapolated, meant that Electronic Arts was claiming it 10 would report Q4 2005 EPS of $0.28-$0.33 (excluding charges). As The Street.com noted: 11 For its full fiscal year, EA predicted that it would earn $1.82 to $1.87 a share – or $1.90 to $1.95 a share, excluding charges – on sales ranging from $3.275 billion 12 to $3.325 billion. Given the company’s performance through its first three quarters that outlook implies that it expects to earn 25 cents to 30 cents a share – 28 cents to 13 33 cents a share excluding charges – on sales ranging from $700 million to $750 million in its fourth quarter. 14 44. Immediately after those January 25, 2005 phenomenal (albeit false) projections, 15 defendants watched the Company’s shares soar almost 10% in a single day. In truth, not only did 16 these projections cause the Company’s shares to be artificially inflated, but these projections 17 reversed the trend of the Company’s shares which had fallen into a decline since late December 18 2004. With the shares reinvigorated, defendants then embarked on a plan to reap tens of millions of 19 dollars in insider trading proceeds. 20 45. On January 28, 2005, defendant Mattrick sold 275,000 of his Electronic Arts shares at 21 $62.11 per share for proceeds of over $17 million. 22 46. Also on January 28, 2005, defendant Reuff sold 40,000 of his Electronic Arts shares 23 at $62.66 per share for proceeds of over $2.5 million. 24 47. Between January 28 and 31, 2005, defendant Smith sold 68,139 of her Electronic Arts 25 shares at $61.50-$63.46 per share for proceeds of over $4.2 million. 26 27 1 The Company’s fiscal year 2005 ends March 31, 2005. 28

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1 48. Between January 28 and 31, 2005, defendant Jenson sold 200,000 of his Electronic 2 Arts shares at $62.18-$62.90 per share for proceeds of over $12.5 million. 3 49. Between January 28 and 31, 2005, defendant Florin sold 60,000 of his Electronic Arts 4 shares at $62.60-$64.20 per share for proceeds of over $3.8 million. 5 50. On January 31, 2005, defendant Probst sold 100,000 of his Electronic Arts shares at 6 $63.72 per share for proceeds of over $6.3 million. 7 51. Between February 1 and 2, 2005, defendant McMillan sold 125,000 of his Electronic 8 Arts shares for $64.92-$65.64 per share for proceeds of over $8.1 million. 9 52. On February 2, 2005, defendant Linzner sold 27,000 of his Electronic Arts shares at 10 $65.44 per share for proceeds of over $1.7 million. 11 53. In less than one week, defendants reaped millions by selling their own shares to 12 genuine investors who paid artificially high prices for the shares 13 54. On March 21, 2005, the Company issued a press release entitled “Electronic Arts 14 Updates Fiscal Year 2005 Estimates.” The press release stated in part: 15 Electronic Arts today announced revised estimates for the Company’s fiscal year ending March 31, 2005. The changes are primarily the result of lower than expected 16 sales in both North America and in Europe. 17 The Company now expects fiscal year 2005 net revenue to be between $3.100 and $3.125 billion, as compared to the Company’s previous estimate of between 18 $3.275 and $3.325 billion. 19 Non-GAAP diluted earnings per share are now expected to be between $1.70 and $1.72 as compared to the Company’s previous estimate of $1.90 to $1.95. 20 GAAP diluted earnings per share are now expected to be between $1.62 and 21 $1.64 – as compared to the Company’s previous estimate of $1.82 to $1.87. 22 “These results are clearly disappointing,” said Larry Probst, Chairman and Chief Executive Officer. “While our new releases are performing reasonably well, 23 they have not been able to offset a significant falloff in catalog sales.” 24 55. In response to revelations of the Company’s inaccurate projections and questionable 25 explanation for the Company’s various failures, the Company’s shares were pummeled by a massive 26 wave of selling which exceeded 39 million shares in a single day. Class members incurred hundreds 27 of millions in losses as a result of defendants’ scheme to line their own pockets. On March 22, 2005, 28 shares of the Company fell $11.20 per share, to close at $55.15 per share.

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1 56. The true facts, which were known by each of the defendants but concealed from the 2 investing public during the Class Period, were as follows: 3 (a) The Company was experiencing a dramatic adverse trend in the Company’s 4 catalog sales of its holiday releases; 5 (b) The Company’s internal numbers were revealing that contrary to growth, the 6 Company was actually experiencing year-over-year decline in revenue and market share in the 7 Company’s Q4 2005 (this followed similar results in Q3 2005); 8 (c) Due to a lack of game consoles (which were necessary for utilizing 9 defendants’ products) defendants knew that consumer demand would dramatically deteriorate while 10 the Company’s public forecasting actually called for increasing sales growth; and 11 (d) As a result of (a) – (c) above, the Company’s claim of achieving FY 2005 EPS 12 growth reaching $1.82-$1.87 per share was materially overstated. Moreover, the extrapolation of the 13 Company’s claims that it would achieve revenue for Q4 2005 of $700 to $750 million and EPS of 14 $0.28-$0.33 was grossly overstated. In fact, the Q4 2005 revenue claims are overstated by hundreds 15 of millions of dollars, and the Q4 2005 EPS claims were overstated by 200-300%, as the Company 16 now admits that FY 2005 EPS will be some $0.20 less than prior statements. 17 FIRST CLAIM FOR RELIEF 18 For Violation of §10(b) of the 1934 Act and Rule 10b-5 Against All Defendants 19 57. Plaintiff incorporates ¶¶1-56 by reference. 20 58. During the Class Period, defendants disseminated or approved the false statements 21 specified above, which they knew or deliberately disregarded were misleading in that they contained 22 misrepresentations and failed to disclose material facts necessary in order to make the statements 23 made, in light of the circumstances under which they were made, not misleading. 24 59. Defendants violated §10(b) of the 1934 Act and Rule 10b-5 in that they: 25 (a) Employed devices, schemes, and artifices to defraud; 26 27 28

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1 (b) Made untrue statements of material facts or omitted to state material facts 2 necessary in order to make the statements made, in light of the circumstances under which they were 3 made, not misleading; or 4 (c) Engaged in acts, practices, and a course of business that operated as a fraud or 5 deceit upon plaintiff and others similarly situated in connection with their purchases of Electronic 6 Arts publicly traded securities during the Class Period. 7 60. Plaintiff and the Class have suffered damages in that, in reliance on the integrity of 8 the market, they paid artificially inflated prices for Electronic Arts publicly traded securities. 9 Plaintiff and the Class would not have purchased Electronic Arts publicly traded securities at the 10 prices they paid, or at all, if they had been aware that the market prices had been artificially and 11 falsely inflated by defendants’ misleading statements. 12 61. As a direct and proximate result of these defendants’ wrongful conduct, plaintiff and 13 the other members of the Class suffered damages in connection with their purchases of Electronic 14 Arts publicly traded securities during the Class Period. 15 SECOND CLAIM FOR RELIEF 16 For Violation of §20(a) of the 1934 Act Against All Defendants 17 62. Plaintiff incorporates ¶¶1-61 by reference. 18 63. The Individual Defendants acted as controlling persons of Electronic Arts within the 19 meaning of §20(a) of the 1934 Act. By reason of their positions as officers and/or directors of 20 Electronic Arts and their ownership of Electronic Arts stock, the Individual Defendants had the 21 power and authority to cause Electronic Arts to engage in the wrongful conduct complained of 22 herein. Electronic Arts controlled each of the Individual Defendants and all of its employees. By 23 reason of such conduct, the Individual Defendants and Electronic Arts are liable pursuant to §20(a) 24 of the 1934 Act. 25 26 27 28

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1 CLASS ACTION ALLEGATIONS 2 64. Plaintiff brings this action as a class action pursuant to Rule 23 of the Federal Rules 3 of Civil Procedure on behalf of all persons who purchased Electronic Arts publicly traded securities 4 on the open market during the Class Period (the “Class”). Excluded from the Class are defendants. 5 65. The members of the Class are so numerous that joinder of all members is 6 impracticable. The disposition of their claims in a class action will provide substantial benefits to 7 the parties and the Court. Electronic Arts had more than 307 million shares of stock outstanding, 8 owned by hundreds if not thousands of persons. 9 66. There is a well-defined community of interest in the questions of law and fact 10 involved in this case. Questions of law and fact common to the members of the Class which 11 predominate over questions which may affect individual Class members include: 12 (a) Whether the 1934 Act was violated by defendants; 13 (b) Whether defendants omitted and/or misrepresented material facts; 14 (c) Whether defendants’ statements omitted material facts necessary to make the 15 statements made, in light of the circumstances under which they were made, not misleading; 16 (d) Whether defendants knew or deliberately disregarded that their statements 17 were false and misleading; 18 (e) Whether the prices of Electronic Arts’ publicly traded securities were 19 artificially inflated; and 20 (f) The extent of damage sustained by Class members and the appropriate 21 measure of damages. 22 67. Plaintiff’s claims are typical of those of the Class because plaintiff and the Class 23 sustained damages from defendants’ wrongful conduct. 24 68. Plaintiff will adequately protect the interests of the Class and has retained counsel 25 who are experienced in class action securities litigation. Plaintiff has no interests which conflict 26 with those of the Class. 27 69. A class action is superior to other available methods for the fair and efficient 28 adjudication of this controversy.

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1 PRAYER FOR RELIEF 2 WHEREFORE, plaintiff prays for judgment as follows: 3 A. Declaring this action to be a proper class action pursuant to FRCP 23; 4 B. Awarding plaintiff and the members of the Class damages, including interest; 5 C. Awarding plaintiff reasonable costs, including attorneys’ fees; and 6 D. Awarding such equitable/injunctive or other relief as the Court may deem just and 7 proper. 8 JURY DEMAND 9 Plaintiff demands a trial by jury. 10 DATED: April 13, 2005 LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 11 PATRICK J. COUGHLIN 12 13 PATRICK J. COUGHLIN 14 100 Pine Street, Suite 2600 15 San Francisco, CA 94111 Telephone: 415/288-4545 16 415/288-4534 (fax) 17 LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 18 WILLIAM S. LERACH DARREN J. ROBBINS 19 401 B Street, Suite 1600 San Diego, CA 92101 20 Telephone: 619/231-1058 619/231-7423 (fax) 21 Attorneys for Plaintiff 22 23 24 25 26 27 28

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1 CERTIFICATION OF INTERESTED ENTITIES OR PERSONS 2 Pursuant to Civil L.R. 3-16, the undersigned certifies that as of this date, other than the 3 named parties, there is no such interest to report. 4 ______5 ATTORNEY OF RECORD FOR PLAINTIFF DANIEL SWANTKO 6

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