Einspahr v. Groupon, Inc. et al

Filing 1

COMPLAINT filed by Dennis Einspahr; Y. Filing fee $ 350, receipt number 0752-7026052. (Attachments: # 1 Certification of Plaintiff)(Wexler, Kenneth)

CERTIFICATION OF PLAINTIFF PURSUANT
TO THE FEDERAL SECURITIES LAWS
I, Dennis Einspahr, declare the following as to the claims asserted, or to be
asserted, under the federal securities laws:
1.

I have reviewed the complaint against Groupon, Inc., the officers and

directors of Groupon, Inc. and the underwriter defendants, prepared by Girard Gibbs LLP
and Wexler Wallace LLP, whom I designate as my counsel in this action for all purposes.
At this time, I adopt the allegations in the complaint.
2.

I did not acquire Groupon common stock at the direction of Girard Gibbs

LLP or Wexler Wallace LLP in order to participate in any private action under the federal
securities laws.
3.

I am willing to serve as a named plaintiff. I understand that a named

plaintiff is a representative party who acts on behalf of other class members in directing
the litigation, and whose duties may include testifying at deposition or trial.
4.

I will not accept any payment for serving as a representative party beyond

my pro rata share of any recovery, except reasonable costs and expenses, such as lost
wages and travel expenses, directly related to the class representation, as ordered or
approved by the Court pursuant to law.
5.

I have not sought to serve or served as a representative party for a class in

any action under the federal securities laws within the past three years.
6.

I understand that this is not a claim form, and that my ability to share in

any recovery as a class member is not affected by my decision to serve as a representative
party.

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APPENDIX A
Summary of Dennis Einspahr’s Purchases and Sales of Groupon Common Stock

TRADE DATE

NUMBER OF SHARES

PRICE PER SHARE

BUY OR SELL

2/14/2012

190

20.57

Buy

3/8/2012

90

18.37

Sell

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