United States District Court Southern District of New York
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x LYDIA GARCIA, Individually and On Behalf : Civil Action No. of All Others Similarly Situated, : : CLASS ACTION COMPLAINT FOR Plaintiff(s), : VIOLATIONS OF FEDERAL SECURITIES : LAWS vs. : : JAKKS PACIFIC, INC., JACK FRIEDMAN, : JURY TRIAL DEMANDED STEPHEN BERMAN, and JOEL BENNETT, : Defendant(s). x Plaintiff has alleged the following based upon the investigation of Plaintiff=s counsel, which included a review of United States Securities and Exchange Commission (“SEC”) filings by JAKKS Pacific, Inc. (“JAKKS” or the ACompany”), as well as regulatory filings and reports, securities analysts’ reports and advisories about the Company, press releases and other public statements issued by the Company, a review of the complaint filed in the case captioned World Wrestling Entertainment, Inc. V. JAKKS Pacific, Inc. et al., 04 CV 8223 (S.D.N.Y.) and media reports about the Company, and Plaintiff believes that substantial additional evidentiary support will exist for the allegations set forth herein after a reasonable opportunity for discovery. NATURE OF THE ACTION 1. This is a federal securities class action on behalf of purchasers of the common stock of JAKKS between February 17, 2004 and October 19, 2004, inclusive (the “Class Period”), seeking to pursue remedies under the Securities Exchange Act of 1934 (the “Exchange Act”). JURISDICTION AND VENUE 2. The claims asserted herein arise under and pursuant to Sections 10(b) and 20(a) of the Exchange Act [15 U.S.C. §§78j(b) and 78t(a)] and Rule 10b-5 promulgated thereunder by the Securities and Exchange Commission (“SEC”) [17 C.F.R.
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