STEC Complaint FILED 10 25 12.pdf
Plaintiff William A. Sokolowski, by his undersigned counsel, alleges the
following upon personal knowledge as to himself and his own acts, and upon
information and belief as to all other matters.1 Plaintiff’s information and belief as
to allegations concerning matters other than himself and his own acts is based upon
an investigation by his counsel, which included, among other things (i) review of
documents filed publicly by STEC with the Securities and Exchange Commission
(the “SEC”); (ii) review and analysis of press releases, news articles, earnings
conference call transcripts and other public statements issued by or concerning
STEC; (iii) review and analysis of research reports issued by financial analysts
concerning STEC’s securities and business; (v) review and analysis of news
articles, media reports and other publications concerning the computer industry;
(vi) review of the Court’s orders and other documents filed of record in In re
STEC, Inc., Securities Litigation, No. SACV 09-0103-JVS (MLGx) (C.D.
Cal.)(“Securities Litigation”)2 and (vii) review of the SEC’s Complaint in
Securities and Exchange Commission v. Manouchehr Moshayedi, Case No.
SACV12-1179 JST (MLGx) (C.D. Cal.) (the “SEC Litigation”). Plaintiff believes
that substantial additional evidentiary support for the allegations herein exists and
will continue to be revealed after he has a reasonable opportunity for discovery.
Plaintiff brings this action individually, asserting claims for violation
of the federal securities laws against Defendant Raymond D. Cook (“Cook”), Rajat
Bahri (“Bahri”), Manouchehr Moshayedi (“Manouchehr”) and Mehrdad
The three Moshayedi family trusts are the respective alter egos of the three
Moyashedi brothers and their knowledge is imputed to such Trusts and vice-versa
(the “Trust Defendants”).
Because of the substantial efforts put into drafting the Complaints in the SEC and
Securities Litigation, Plaintiff has utilized and quoted directly certain allegations
from, inter alia, the Complaint in the SEC Litigation and the Second Consolidated
Amended Complaint in the Securities Litigation, both of which are incorporated
herein by reference.