Glassman v. Computervision

Case Date: 07/31/1996
Court: United States Court of Appeals
Docket No: 95-2240










United States Court of Appeals
For the First Circuit
____________________

No. 95-2240

MORRIS I. GLASSMAN, et al.,

Plaintiffs, Appellants,

v.

COMPUTERVISION CORPORATION, et al.,

Defendants, Appellees.

____________________


APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

[Hon. William G. Young, U.S. District Judge] ___________________

____________________

Before

Lynch, Circuit Judge, _____________

Coffin, Senior Circuit Judge, ____________________

Cummings, Circuit Judge.* _____________

____________________

Peter J. Macdonald, with whom Jeffrey B. Rudman, David E. Marder, __________________ __________________ _______________
S. Tara Miller, Hale and Dorr, Bruce D. Angiolillo, Nicholas Even, ________________ ______________ ___________________ _____________
Elisabeth Bassin, Simpson Thacher & Bartlett, Thomas J. Dougherty, _________________ ____________________________ ____________________
Dennis M. Kelleher, and Skadden, Arps, Slate, Meagher & Flom, were on __________________ _____________________________________
brief, for the defendants-appellees.

Thomas G. Shapiro, with whom Michelle Blauner, Shapiro Grace __________________ _________________ ______________
Haber & Urmy, Glen DeValerio, Norman Berman, Michael Lange, Berman _____________ _______________ ______________ ______________ ______
DeValerio & Pease, Daniel W. Krasner, Peter C. Harrar, Wolf ___________________ ____________________ __________________ ____


____________________

*Of the Seventh Circuit, sitting by designation.















Haldenstein Adler Freeman & Herz, L.L.P., I. Stephen Rabin, Joseph P. _________________________________________ ________________ _________
Garland, and Rabin & Garland, were on brief, for the plaintiffs- _______ ________________
appellants.


____________________

July 31, 1996
____________________























































LYNCH, Circuit Judge. Computervision Corporation, LYNCH, Circuit Judge. _____________

a Massachusetts high technology company, made an initial

public offering ("IPO") of securities on August 14, 1992.

Six weeks later, on September 29, 1992, Computervision

announced that its revenues and operating results for the

third quarter of 1992 would be lower than expected. The

prices of Computervision's stock and notes fell sharply. On

the day after this announcement, the first investor suit was

filed. Computervision and the IPO underwriters were sued

under Sections 11 and 12(2) of the Securities Act of 1933

(the "Securities Act"). The investors also sued

Computervision's principal officers and directors, alleging

controlling person liability under Section 15 of the

Securities Act. Plaintiffs asserted that they represented

the class of investors who purchased common stock or notes

between August 14, 1992 and September 29, 1992. The district

court, after lengthy pre-trial proceedings and full

discovery, both dismissed the case for failure to state a

claim and denied as futile plaintiffs' motion for leave to

file a second amended complaint. See In re Computervision ___ ____________________

Corp. Sec. Litig. ("Computervision II"), 914 F. Supp. 717, __________________ __________________

719 (D. Mass. 1996).

The investors appeal from the denial of their

motion for leave to amend, arguing that their proposed second

amended complaint (the "Proposed Complaint") passed the Rule



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12(b)(6) threshold. They say the Proposed Complaint

adequately alleged violations of the securities laws in that

the Prospectus1 for the IPO contained actionable

misrepresentations,"half-truths" or omissions regarding: (1)

the factors considered in determining the prices for the

offerings; (2) certain mid-quarter information for the third

quarter of 1992; (3) the importance of Computervision's low

backlog; (4) the latest release of Computervision's key new

software product, CADDS 5, which Computervision said was

commercially shipping when (plaintiffs say) it was not, and

the development and commercial prospects of CADDS 5.

We affirm, although our reasoning as to the first

claim differs from that of the district court.

I.

Background __________

Computervision is a leading supplier of work

station-based computer aided design and computer aided

manufacturing ("CAD/CAM") software and related services to

the mechanical design automation market. Its software

products are utilized in the design of complex parts and

assemblies for the automotive, aerospace, and other

mechanical industries. Its products enable users to reduce


____________________

1. The term "Prospectus" will be used throughout although
there were two prospectuses, one for stock and one for notes.
The parties treat them as identical for all material
purposes.

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the time required for designing, engineering and

manufacturing a product before market introduction. This

"time-to-market" is a key factor in ensuring profitability

and competitiveness.2

The company was organized in 1972 under the name

Prime Computer, Inc.3 Until 1988, Prime was in the business

of making and selling computer systems. In 1988, Prime

acquired Computervision Corporation, a leading supplier of

CAD/CAM hardware and software products. In 1989, the company

was acquired by DR Holdings, and shifted its focus from

computer systems to the CAD/CAM market. A principal

shareholder of DR Holdings, Shearson Holdings,4 provided the

company with a $500 million bridge loan in connection with

the acquisition. That bridge loan was intended to be repaid

with the proceeds from a high-yield bond offering. However,

that offering never occurred and Computervision instead


____________________

2. At the time of the IPO, Computervision had an installed
base of 58,000 units, predominantly in North America and
Europe. In 1991, international revenues accounted for
approximately 66% of its total revenues.

3. The company's name was changed to Computervision Corp. at
the time of the IPO at issue here. For clarity, we refer to
the company as "Computervision" throughout.

4. Shearson Holdings is the parent company of a co-lead
underwriter for the IPO, Shearson Lehman Brothers, Inc. In
addition to Shearson Holdings and its affiliate, Shearson
Lehman Brothers Capital Partners II, L.P., the principal
shareholders of DR Holdings were J.H. Whitney & Co. and
affiliates and the Prudential Insurance Company of America
and affiliates.

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refinanced the bridge loan with $500 million in notes. In

December 1991, interest on the notes was itself converted

from cash payments to payments "in kind," i.e., additional ____

notes.

The proceeds from the IPO were intended to repay

half the principal amount, of the notes held by Shearson

Holdings, with the rest of the debt to Shearson Holdings to

be converted to Computervision common stock or written off by

Shearson. Both Shearson Holdings and DR Holdings signed

"lock-up" agreements, promising not to sell their equity

positions in Computervision until a year after the IPO.

Plaintiffs posit that Computervision's worsening financial

condition5 placed Shearson Holdings' investment in jeopardy

by increasing the likelihood that Computervision would

default on its debt to Shearson Holdings. Allegedly, the

solution was to take the company public and use the proceeds

to repay a substantial portion of the debt. Plaintiffs say

that defendants believed that if Computervision was not taken

public during the summer of 1992, the opportunity for

Shearson Holdings to recoup its investment would be lost.

____________________

5. In the three and a half years prior to the IPO,
Computervision suffered close to $1 billion in losses. In
1989, its net losses were $281 million; in 1990, $71 million;
in 1991, $461 million; and for the first six months of 1992,
$143 million. Computervision's CAD/CAM revenues for the
first six months of 1992 decreased by 5% from the
corresponding period in 1991. However, software revenues
from the CADDS line increased 10% from the corresponding
period in 1991.

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On August 14, 1992, Computervision sold $600

million of securities in a registered IPO. The offering was

composed of 25 million shares of common stock at $12 a share

(for a total of $300 million); $125 million of 10-7/8% Senior

Notes due 1997; and $175 million of 11-3/8% Senior

Subordinated Notes due 1999. The Computervision IPO was a

firm-commitment underwriting, in which the underwriters

purchased the securities from the company and assumed the

risk that the market would not accept the securities at the

price set. See Shaw v. Digital Equipment Corp., 82 F.3d ___ ____ ________________________

1194, 1200 n.1 (1st Cir. 1996). Shearson Lehman Brothers,

Inc., Donaldson, Lufkin & Jenrette Securities Corp., The

First Boston Corp., and Hambrecht & Quist, Inc., were the co-

lead underwriters for the domestic offering, representing a

syndicate of over forty firms.

On September 29, 1992, six weeks after the

offering, Computervision announced that its revenue and

operating results for the third quarter of 1992 would be

below expectations. Within a day, the stock price fell 30%,

to $6.25, and the notes were trading at approximately 8%

below face value.

On October 22, 1992, Computervision quantified its

results for the third quarter, which ended on September 27,

1992. Computervision had suffered a net loss of roughly $88

million, including a $25 million non-recurring charge



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occasioned by its decision to lay off more than 11% of its

work force.

II.

Description of Actions and Procedural History _____________________________________________

On September 30, 1992, one day after Computervision

announced that its operating results for the third quarter of

1992 would be lower than expected, plaintiffs filed the first

of eighteen separate complaints. In addition to claims under

Sections 11, 12(2) and 15 of the Securities Act, plaintiffs

asserted a violation of Section 10(b) of the Securities

Exchange Act of 1934 and negligent misrepresentation.

The eighteen actions were consolidated into one

class action and on June 11, 1993, plaintiffs filed a

Corrected Supplemental Consolidated Amended Class Action

Complaint (the "1993 Amended Complaint").6 Among other

things, the 1993 Amended Complaint alleged that the

Prospectus: (i) distorted Computervision's earning trends;

(ii) omitted disclosure of known uncertainties impacting upon

Computervision's operating results; (iii) omitted disclosure

of the increasing likelihood that Computervision would not

meet its internally projected results for 1992; (iv) omitted


____________________

6. The 1993 Amended Complaint formally withdrew any claims
of fraud under section 10(b). Nevertheless, the district
court ruled that the complaint sounded in fraud and that Fed.
R. Civ. P. 9(b)'s strict pleading standards applied. See In ___ __
re Computervision Corp. Sec. Litig. ("Computervision I"), 869 ___________________________________ ________________
F. Supp. 56, 63-64 (D. Mass. 1994).

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disclosure of known declines in the demand for

Computervision's services and products; and (v) omitted

disclosure of software development problems.

On November 23, 1993, the district court heard

argument on defendants' motion to dismiss. While the motion

was under advisement, discovery commenced. Discovery was

extensive. Plaintiffs reviewed more than 130,000 documents

and deposed over twenty witnesses. Plaintiffs have

represented that, should the case be reinstated, it does not

require the reopening of discovery.

On November 22, 1994, the district court issued its

decision, dismissing all but a sliver of the claims,

primarily on the grounds that they failed to satisfy the

requirements of Fed. R. Civ. P. 12(b)(6) and 9(b). See ___

Computervision I, 869 F. Supp. at 64. The district court ________________

noted that the Prospectus warned investors of the risks

involved and that, with one exception, the alleged

misrepresentations were made in a context that adequately

"bespoke caution." Id. at 60-61. As to the omissions, the ___

court noted that these, in large part, referred either to

information that was effectively disclosed, or to information

for which there was no duty to disclose. Id. at 62-63. ___

On January 20, 1995, plaintiffs served a motion for

leave to file a second amended complaint. Defendants served

their opposition to that motion on February 24, 1995 and



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moved for summary judgment on the sole allegation surviving

the district court's 1994 decision.7 The parties then

entered into a Stipulation of Dismissal, dismissing, with

prejudice, the surviving claim. The stipulation was to be

effective the day after the district court ruled on the _____

motion for leave to amend.

On May 1, 1995, plaintiffs moved for leave to file

the Proposed Complaint at issue here. The court heard

argument on September 13, 1995, and a week later, on

September 20, denied the motion for leave to amend. The

basis for the denial was futility, in that the Proposed

Complaint failed to state a claim pursuant to Rule 12(b)(6).

The court dismissed the case, entered judgment for the

defendants, and promised a full opinion.

Plaintiffs filed their notice of appeal on October

20, 1995. Subsequently, on February 12, 1996, the district

court issued an opinion setting forth the rationale

underlying its September 1995 order. Computervision II, 914 _________________

F. Supp. at 717-22. The one claim that had given the

district court pause at oral argument was the allegation that

the Prospectus had misrepresented that the securities were

"appropriately" priced. The district court nevertheless ruled


____________________

7. Pursuant to the parties' Rule 16.1(D) Joint Statement
filed December 28, 1994, plaintiffs' proposed amended
complaint and summary judgment motions were served but not
filed with the court.

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that that claim failed because: (a) the Prospectus had not

warranted or insured the appropriateness of the securities'

prices; and (b) the claim was keyed to the nondisclosure of

internal projections, which were not required to be disclosed

in any event. Id. at 719-20. The district court ruled that ___

plaintiffs' other misrepresentation claims, relating to

backlog and CADDS 5, failed because they were based on

unreasonable inferences drawn by reading statements in the

Prospectus out of context.8 Id. at 719-22. This appeal ___

followed.

III.

Analysis ________

A. Standard of Review __________________

This appeal lies from the district court's denial

of plaintiffs' motion to file an amended complaint. The

motion was denied after full discovery and after the

dismissal of an earlier complaint. The district court ruled

that amendment would be futile. The parties disagreed then,

as they do now, over the proper standard for analyzing this

motion to amend. See id. at 719. Plaintiffs argued that ___ ___

leave to amend should be "freely given when justice so

requires," Fed. R. Civ. P. 15(a). Computervision II, 914 F. _________________


____________________

8. Since there were no actionable misstatements or
omissions, the court held that the negligent
misrepresentation claim against the underwriters failed as
well. Computervision II, 914 F. Supp. at 722. _________________

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Supp. at 719. Defendants embraced the more stringent

"substantial and convincing evidence" standard set forth in

Resolution Trust Corp. v. Gold, 30 F.3d 251, 253 (1st Cir. _______________________ ____

1994). Computervision II, 914 F. Supp. at 719. The district _________________

court did not decide the issue, finding the question academic

"as the plaintiffs cannot maintain this action under either

standard." Computervision II, 914 F. Supp. at 719. _________________

Denial of a motion to file an amended complaint is

reviewed for abuse of discretion. See Romani v. Shearson ___ ______ ________

Lehman Hutton, 929 F.2d 875, 880 (1st Cir. 1991); Arazie v. ______________ ______

Mullane, 2 F.3d 1456, 1464-65 (7th Cir. 1993) (noting, _______

however, that the relevant pleading standards must be kept in

mind when applying the abuse of discretion standard). Rule

15(a) provides that "leave [to amend] shall be freely given

when justice so requires." Unless there appears to be an

adequate reason for the denial of leave to amend (e.g., undue ____

delay, bad faith, dilatory motive, futility of amendment,

prejudice), we will not affirm it. Grant v. News Group _____ __________

Boston, Inc., 55 F.3d 1, 5 (1st Cir. 1995). ____________

Here, there was no finding that plaintiffs acted in

bad faith, or in an effort to prolong litigation. Nor was

there a finding that defendants would have been prejudiced by









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the amendment.9 See Ward Electronics Serv., Inc. v. First ___ _____________________________ _____

Commercial Bank, 819 F.2d 496, 496-97 (4th Cir. 1987). _______________

Rather, the dismissal rested on other grounds. The

district court's order explicitly states: "the motion to

further amend the complaint is denied as futile." "Futility"

means that the complaint, as amended, would fail to state a

claim upon which relief could be granted. See 3 Moore's ___ _______

Federal Practice 15.08[4], at 15-80 (2d ed. 1993); see also ________________ ___ ____

Vargas v. McNamara, 608 F.2d 15, 17 (1st Cir. 1979). In ______ ________

reviewing for "futility," the district court applies the same

standard of legal sufficiency as applies to a Rule 12(b)(6)

motion. 3 Moore's, at 15.08[4], at 15-81. _______

The Gold standard, which requires that proposed ____

amendments have substantial merit and be supported by

substantial and convincing evidence, is inapplicable for

several reasons. To date, it has only been applied where the

motion to amend is made after a defendant has moved for _____

summary judgment. See e.g., Gold, 30 F.3d at 253; Torres- ___ ____ ____ _______

Matos v. St. Lawrence Garment Co., 901 F.2d 1144, 1146 (1st _____ _________________________

____________________

9. It is unlikely that defendants could have been
prejudiced. Plaintiffs have represented that the allegations
of the Proposed Complaint do not require reopening discovery.
There is also no claim that defendants would need additional
time to change their trial strategy in light of the proposed
amendment. Cf. Tiernan v. Byth, Eastman, Dillon & Co., 719 ___ _______ ____________________________
F.2d 1, 4-5 (1st Cir. 1983) (finding prejudice even where
additional discovery was not necessary; the additional claims
"may well have affected defendants' planned trial strategy
and tactics" and both defendants and the court would likely
have "required additional time to prepare for trial").

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Cir. 1990); Cowen v. Bank United of Texas, FSB, 1995 WL _____ ___________________________

38978, *9 (N.D. Ill.), aff'd 70 F.3d 937 (7th Cir. 1995); _____

Carey v. Beans, 500 F. Supp. 580, 582 (E.D. Pa. 1980), aff'd, _____ _____ _____

659 F.2d 1065 (3d Cir. 1981); Artman v. International ______ _____________

Harvester Co., 355 F. Supp. 476, 481 (W.D. Pa. 1972). In _____________

that context, a plaintiff's motion to amend is an attempt to

alter the shape of the case in order to defeat summary

judgment.

Here plaintiffs served the motion to amend before ______

defendants moved for summary judgment. Further, the claims

in the summary judgment motion were dropped by agreement of _________

the parties and, as a result, no summary judgment motion was

pending when the district court considered the motion to

amend.

Nor does Gold apply by analogy. This is not a ____

situation in which plaintiffs seek amendment solely to avert

imminent defeat. Cf. Cowen v. Bank United of Texas, FSB, 70 ___ _____ __________________________

F.3d 937, 944 (7th Cir. 1995). Nor is this a situation in

which it is rational to presume that defendants would be

prejudiced by amendment. Cf. Carey v. Beans, 500 F. Supp. at ___ _____ _____

582 (calling prejudice to non-movant the "`touchstone for the

denial of the amendment'" (quoting Cornell & Co. v. OSHA, 573 _____________ ____

F.2d 820, 823 (8th Cir. 1978)). Although, under these

circumstances, plaintiffs could be guilty of undue delay or

prejudice to defendants might exist, the district court made



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no such finding. Further, the district court did not rely on

Goldandits reasoningwas almostpurelya legalfutility analysis. ____

Thus, we look at whether the district court

correctly determined that the Proposed Complaint failed to

meet the pleading standards of Rule 12(b)(6). There is no

practical difference, in terms of review, between a denial of

a motion to amend based on futility and the grant of a motion

to dismiss for failure to state a claim. See Motorcity of ___ _____________

Jacksonville, Ltd. v. Southeast Bank, 83 F.3d 1317, 1323 ___________________ ______________

(11th Cir. 1996); see also Keweenaw Bay Indian Community v. ___ ____ ______________________________

Michigan, 11 F.3d 1341, 1348 (6th Cir. 1993). Review is de ________ __

novo. See, e.g., Serabian v. Amoskeag Bank Shares, Inc., 24 ____ ___ ____ ________ __________________________

F.3d 357, 361 (1st Cir. 1994) (motions to dismiss are

reviewed de novo). __ ____

B. Securities Law Claims _____________________

"Sections 11 and 12(2) are enforcement mechanisms

for the mandatory disclosure requirements of the Securities

Act." Shaw, 82 F.3d at 1201. Section 11 imposes liability ____

on signers of a registration statement and on underwriters,

among others, if the registration statement "contained an

untrue statement of a material fact or omitted to state a

material fact required to be stated therein or necessary to

make the statements therein not misleading." 15 U.S.C.

77k(a). Section 12(2) provides that any person who "offers

or sells" a security by means of a prospectus or oral



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communication that contains a materially false statement or

that "omits to state a material fact necessary to make the

statements, in the light of the circumstances under which

they were made, not misleading" shall be liable to any

"person purchasing such security from him." 15 U.S.C.

77l(2).

As we said in Shaw, there is a strong affirmative ____

duty of disclosure in the context of a public offering. 83

F.3d at 1202. The same may be even more emphatically true in

an initial public offering, where the securities have not

before been publicly traded. Cf. Marcel Kahan, Securities ___ __________

Laws and the Social Costs of "Inaccurate" Stock Prices, 41 _________________________________________________________

Duke L.J. 977, 1014-15 (1992). But the main thrust of

plaintiffs' claims is not based on any duty to disclose.

Rather, they say that this is primarily an affirmative

misrepresentation or half-truth case.

The Proposed Complaint centers on the claim that

Computervision affirmatively misrepresented that the offering

price was set after the exercise of due diligence by the

underwriters, but that in fact the diligence exercised was

deficient in that the most current information was not

considered. In addition, plaintiffs contend that the

Prospectus omitted certain mid-quarter information for the

third quarter of 1992 and contained material misstatements or





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omissions regarding Computervision's backlog and the state of

its latest software product, CADDS 5.

The district court held that the Prospectus would

not bear the characterizations plaintiffs sought to place on

it, and that the allegedly actionable "representations" were

no more than unreasonable inferences drawn by plaintiffs and

unsupported by the surrounding language. Computervision II, _________________

914 F. Supp. at 719. Plaintiffs argue that the district

court erred and that they should have been allowed to amend

their complaint.

Defendants respond by asserting that plaintiffs'

pricing claims reduce to an argument that the securities were

mispriced because their prices fell subsequent to the

offerings, and that the omission of mid-quarter information

claims reduce to nothing more than an argument that

Computervision was required to disclose its internal

forecasts. Plaintiffs' position, defendants say, is _________

untenable because the securities laws impose no duty upon a

company to either provide a warranty as to price or to

disclose internal projections. They also say that the

alleged misstatements concerning backlog and CADDS 5 are not

actionably misleading when considered in the context of the

Prospectus as a whole.

1. Pricing/Due Diligence Claims ____________________________





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The Computervision IPO was unusual in one respect

which has bearing on plaintiffs' claims. Computervision had

been owned by an entity, one of whose principal shareholders,

Shearson Holdings, was affiliated with one of the co-lead

underwriters, Shearson Lehman Brothers. As a result, the

Prospectus informed investors:

Under the provisions of Schedule E to the
By-laws of the National Association of
Securities Dealers Inc. ("NASD"), when
NASD members such as Shearson Lehman
Brothers Inc., participate in the
distribution of an affiliate's
securities, the public offering price can
be no higher than that recommended by a
"qualified independent underwriter"
meeting certain standards.

Hambrecht & Quist (for the stock) and Donaldson Lufkin and

First Boston (for the notes) assumed the obligations of due

diligence as to the public offering prices, and the

Prospectus explicitly represented that they had done so.

This representation in the Prospectus is

significant in two respects. First, the fact that one of the

lead underwriters was affiliated with a principal shareholder

of Computervision arguably gave that underwriter a reason to

inflate the offering prices. Second, the Prospectus, in

effect, explicitly assured the members of the investing

public that, despite the link between Shearson Holdings and

Shearson Lehman Brothers, they had no reason to fear an

inflated price. The Prospectus made a selling point out of

the fact that independent underwriters had performed due


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diligence, set maximum prices, and thus acted as gatekeepers

against possible misdeeds by Shearson Holdings and Shearson

Lehman Brothers. Cf. John C. Coffee, Re-Engineering ___ ______________

Corporate Disclosure: The Coming Debate Over Company _____________________________________________________________

Registration, 52 Wash. & Lee L. Rev. 1143, 1168 (1995). ____________

(i) The Pricing Claims in the Proposed Complaint ____________________________________________

The Prospectus described the process by which

Computervision and its underwriters arrived at prices for the

offering:

Prior to the Share Offerings there has
been no public market for the Common
Stock. The initial public offering price
was determined by negotiation among the
Company, the Representatives and the Lead
Managers. Among the factors considered
in determining the initial offering
price, in addition to prevailing market
conditions, was the Company's historical
performance, estimates of the business
potential and earnings prospects of the
Company and market prices of and
financial and operating data concerning
comparable companies.

These representations are at the heart of the

Proposed Complaint, which alleges in paragraphs 3(a) and 45,

respectively:

The Stock Prospectus was misleading in
stating that the Stock had been
appropriately priced. The price of the
Notes was also too high, causing their
yields to be too low. The Stock ___________
Prospectus stated that among the factors _________________________________________
considered in determining the initial _________________________________________
public offering price were "estimates of _________________________________________
the business potential and earnings _________________________________________
prospects of the Company." By the time _________________________________________
of the Offerings, however, those _________________________________________


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estimates were no longer valid. As of ________________________________
the date of the Offerings, the Company's
revenues, bookings, visibility and
backlog were all substantially below the
plan prepared by Computervision and
reviewed by the underwriters in
connection with their due diligence and
pricing for the Offerings (the "IPO
Plan"), as well as the Company's other
internal plans and forecasts (emphasis
added) (footnotes omitted).

The Stock Prospectus represented that the
initial public offering price for the
Stock was based upon, among other things,
"estimates of the business potential and
earnings prospects of the Company . . ."
The Prospectuses also stated that
"qualified independent underwriters" had
recommended the initial public offering
price for the Shares and the yields on
the Notes. Those formal, written
recommendations were based on factors
including "estimates of the business
potential of the company" and on the
"economic, market, financial and other
conditions" as they existed on August 13,
1992, the day before the effective date
of the Offerings. Contrary to the
representations in the Prospectuses, the
price of the Shares and the yields on the
Notes did not properly reflect the
business potential, earnings prospects or
financial condition of Computervision as
of that date.10

____________________

10. Related allegations are found at paragraphs 46 and 84 of
the Proposed Complaint, respectively:

As of the date of the Offerings, all of
Computervision's internal planning and
forecasting devices showed that results
during the first seven weeks of the Third
Quarter were substantially below the
budgets set in the Company's internal
plans and the IPO Plan which the Company
had presented to the Underwriters in
conjunction with their due diligence and
pricing of the Offerings. In particular,

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____________________

at the time of the Offerings,
Computervision's U.S. sales were
materially below sales at comparable
points in the prior five quarters. Both
U.S. and international sales were
substantially below the Company's plans.
In addition, Computervision had a $40
million shortfall in visible orders
needed to reach its quarterly budget.
The Underwriters failed to perform
adequate due diligence on
Computervision's actual revenues, sales,
orders, bookings and visibility for the
seven weeks during the Third Quarter
before the Offerings. The Underwriters _________________
were required to but did not obtain _________________________________________
information necessary to verify the _________________________________________
Company's false statements that such _________________________________________
results were "more or less where they _________________________________________
were expected to be." To the extent the _________________________________________
Underwriters obtained any information _________________________________________
from the Company concerning these _________________________________________
results, the Stock and Notes were _________________________________________
mispriced because the initial offering _________________________________________
price and the yields, as well as _________________________________________
Underwriters' recommendations, did not _________________________________________
take into account these low levels of _________________________________________
sales and the $40 million order _________________________________________
shortfall. Therefore, the representation __________
in the Stock prospectus that the offering
price was based upon "estimates of the
business potential and earnings prospects
of the Company" was false and misleading,
as were the representations in the
Prospectuses concerning the
recommendations of the qualified
independent underwriters (emphasis
added).

The Underwriters failed to perform
adequate due diligence on the Company's
actual sales, orders, bookings,
visibility and backlog for the first
seven weeks of the Third Quarter before
the Offerings. The Underwriters were ______________________
required to but either failed to obtain _________________________________________
and review or ignored information about _________________________________________
actual sales, orders, bookings, _________________________________________

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Different claims, which require different analyses, appear to

be asserted in these paragraphs.

(ii) District Court's Characterization of the _____________________________________________

Pricing Claims ______________

In dismissing the action, the district court

characterized plaintiffs' claim as being that the prices set ______

for the securities were inappropriate. Computervision II, _________________

914 F. Supp. at 720. The district court noted that the

Prospectus never represented that the prices were

"appropriate" and that if the Prospectus language quoted in

paragraph 48 of the Proposed Complaint:

constitutes a representation that the
initial price was 'appropriate,'
investors would effectively have
insurance against any decline in price,
rendering their investments risk-free.

Id. We agree with the district court's view of any claim ___

plaintiffs make that the Prospectus represented that the

price itself was appropriate. We note, however, that

plaintiffs vigorously deny that such was, or is, their claim.




____________________

visibility and backlog necessary to _________________________________________
verify the Company's statements that they _________________________________________
were more or less on track. As a result, __________________________
the Stock and Notes were mispriced
because the initial offering price of the
Stock and the yields on the Notes did not
take into account these adverse results,
including the $40 million order shortfall
(emphasis added).


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The price set for an offering of securities is

essentially a forecast. Price can be characterized as a

present value calculation of the firm's future streams of

earnings or dividends. See In re VeriFone Sec. Litig. ___ _____________________________

("VeriFone I"), 784 F. Supp. 1471, 1479 (N.D. Cal. 1992) ___________

("securities prices on national exchanges reflect . . . the

expected future cash flows from the security"), aff'd, 11 _____

F.3d 865 (9th Cir. 1993); Richard A. Brealey and Stewart C.

Myers, Principles of Corporate Finance, 61-63 (4th ed. 1991); _______________________________

cf. Niagara Hudson Power Corp. v. Leventritt, 340 U.S. 336, ___ ___________________________ __________

339 & n.7 (1951) (approving the SEC's valuation of warrants

in terms of current expectations of future events); Pommer v. ______

Medtest Corp., 961 F.2d 620, 623 (7th Cir. 1992) _______________

("[p]robabilities determine the value of stock"); Wielgos v. _______

Commonwealth Edison Co., 892 F.2d 509, 514 (7th Cir. 1989) ________________________

(investors value securities on the basis of how they believe

the firm will do in the future, and not on past performance).

Since price is only a forecast of the firm's future

performance, it is not actionable merely because the

forecast, in hindsight, does not turn out to be correct. See ___

In re VeriFone Sec. Litig. ("VeriFone II"), 11 F.3d 865, 871 ___________________________ ___________

(9th Cir. 1993) (earnings forecasts made on reasonable basis

not actionable); Wielgos, 892 F.2d at 518; Marx v. Computer _______ ____ ________

Sciences Corp., 507 F.2d 485, 489-90 (9th Cir. 1974). _______________

Forecasts are not guarantees of, or insurance policies for, a



-23- 23













firm's future performance, nor are they understood as such by

reasonable investors. Kowal v. MCI Communications Corp., 16 _____ ________________________

F.3d 1271, 1276 (D.C. Cir. 1994); Raab v. General Physics ____ _______________

Corp., 4 F.3d 286, 290 (4th Cir. 1993). Hence, to the extent _____

plaintiffs' "price" claim rests on either the fact that the

initial offering prices fell shortly after the offering or

the fact that Computervision's third quarter earnings turned

out to be worse than expected, it fails.11 Cf. Pommer, 961 ___ ______

F.2d at 623 ("[S]ecurities laws approach matters from an ex __

ante perspective."). ____

(iii) Plaintiffs' Characterization of the Pricing _____________________________________________

Claims ______

Plaintiffs, however, argue that their attack is not

on the appropriateness of the offering prices themselves.

Instead, they assert that their claim before the district

court was that the Prospectus materially misrepresented that:

____________________

11. In addition, when the Prospectus statements about price
are read in context, they appear to be anything but a
guarantee. First, the Prospectus provided investors with _________
explicit and specific warnings as to factors that might cause
the prices of the securities to fall. Second, the Prospectus
cautioned investors as to the possibility that no market for
the securities would develop or be sustained after the
offering. These cautionary statements in the Prospectus are,
in and of themselves, reason to find this claim not
actionable. See Shaw, 82 F.3d at 1213 ("when statements of ___ ____
`soft' information such as forecasts, estimates, opinions, or
projections are accompanied by cautionary disclosures that
adequately warn of the possibility that actual results or
events may turn out differently, the `soft' statements may
not be materially misleading"); In re Donald J. Trump Casino _____________________________
Sec. Litig., 7 F.3d 357, 371 (3d Cir. 1993)(same). ___________


-24- 24













(a) certain types of information were considered by the

underwriters and Computervision in determining prices for

the offering, when, in fact, the most current information of

those types was not considered (or, if considered, was

ignored); and (b) the underwriters did due diligence in

estimating the prices, when they did not because they did not

consider the most current information.

As a threshold matter, the explicit statements in ________

the Prospectus that certain factors were considered and that

due diligence was done are required by law to be true as of _____

the effective date of the offering. See 15 U.S.C. 77k(a) ___________________________________ ___

(liability attaches for misstatements in a prospectus at the

time such part becomes effective); see also 3A Harold S. ___ ____

Bloomenthal, Securities and Federal Corporate Law 8.23, at _____________________________________

8-102 (1993) ("[