Vladimir Maliarov, Et Al. V. Eros International PLC, Et Al. 15-CV
Case 1:15-cv-08956-AJN Document 1 Filed 11/13/15 Page 1 of 68 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VLADIMIR MALIAROV, Individually and Case No. On Behalf of All Others Similarly Situated, Plaintiff, CLASS ACTION COMPLAINT FOR VIOLATIONS OF THE FEDERAL v. SECURITIES LAWS EROS INTERNATIONAL PLC, JYOTI JURY TRIAL DEMANDED DESHPANDE, ANDREW HEFFERNAN, PREM PARAMESWARAN, KISHORE LULLA, VIJAY AHUJA, NARESH CHANDRA, DILIP THAKKAR, SUNIL LULLA, MICHAEL KIRKWOOD, KEN NAZ, DEUTSCHE BANK SECURITIES INC., MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED, UBS SECURITIES LLC, JEFFERIES LLC, CREDIT SUISSE SECURITIES (USA) LLC, and EM SECURITIES LLC, Defendants. CLASS ACTION COMPLAINT Case 1:15-cv-08956-AJN Document 1 Filed 11/13/15 Page 2 of 68 Plaintiff Vladimir Maliarov (“Plaintiff”), by and through his attorneys, alleges the following upon information and belief, except as to those allegations concerning Plaintiff, which are alleged upon personal knowledge. Plaintiff’s information and belief is based upon, among other things, his counsel’s investigation, which includes without limitation: (a) review and analysis of regulatory filings made by Eros International Plc (“Eros” or the “Company”), with the United States Securities and Exchange Commission (“SEC”); (b) review and analysis of press releases and media reports issued by and disseminated by Eros; and (c) review of other publicly available information concerning Eros. NATURE OF THE ACTION AND OVERVIEW 1. This is a class action on behalf of persons or entities who purchased or otherwise acquired Eros securities: (1) pursuant and/or traceable to the Company’s Registration Statement and Prospectus (collectively, the “Registration Statement”) issued in connection with the Company’s initial public offering on the New York Stock Exchange on or about November 12, 2013 (the “IPO” or the “Offering”); and/or (2) between November 12, 2013 and November 12, 2015, inclusive (the “Class Period”).
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