Securities and Exchange Commission v. Galleon Management, LP et al
Filing
235
DECLARATION of John Henderson in Support re: 232 MOTION for Summary Judgment.. Document filed by Securities and Exchange Commission. (Attachments: # 1 Exhibit A1-A5, # 2 Exhibit A6 pt.1, # 3 Exhibit A6 pt.2, # 4 Exhibit A6 pt.3, # 5 Exhibit A6 pt.4, # 6 Exhibit A7-A9, # 7 Exhibit A-Z, # 8 Exhibit AA-ZZ, # 9 Exhibit AAA-LLL, # 10 Exhibit MMM-ZZZ, # 11 Exhibit AAAA-IIII, # 12 Exhibit JJJJ-QQQQ, # 13 Exhibit RRRR)(Szczepanik, Valerie)
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Exhibit A-2
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
------------------------------------------------------------------------x
SECURITIES AND EXCHANGE COMMISSION,
:
:
Plaintiff,
:
:
- against :
:
GALLEON MANAGEMENT, L.P., et al.,
:
:
Defendants.
:
------------------------------------------------------------------------x
Page 1 of 28
No. 09 Civ. 8811 (JSR)
ECF CASE
ANSWER OF GALLEON MANAGEMENT, L.P. TO THE
SECOND AMENDED COMPLAINT
Defendant Galleon Management, L.P. (“Galleon”) states as follows for its Answer
in response to the Second Amended Complaint, dated January 29, 2010 (the “Second Amended
Complaint”). To the extent that certain paragraphs in the Second Amended Complaint include
allegations against defendants other than Galleon, Galleon’s responses to the allegations
contained in such paragraphs, set forth herein, relate to Galleon only and to no other defendant.
To the extent allegations in the Second Amended Complaint purport to summarize, paraphrase or
quote oral conversations involving representatives of Galleon, Galleon has, where applicable,
relied on the Answer in this action of the representative who allegedly participated in the
conversation.
1.
Galleon denies the allegations in Paragraph 1, except admits that the
allegations purport to describe Plaintiff’s claims.
2.
Galleon denies the allegations in Paragraph 2, except admits that the
allegations purport to describe Plaintiff’s claims.
3.
To the extent the allegations in Paragraph 3 state legal conclusions, no
response is required. To the extent a response is required, Galleon admits that Plaintiff purports
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to bring this action pursuant to the statutes cited in Paragraph 3, and that Plaintiff purports to
seek the relief described in Paragraph 3.
4.
To the extent the allegations in Paragraph 4 state legal conclusions, no
response is required. To the extent a response is required, Galleon admits that Plaintiff purports
to base jurisdiction over the subject matter of this action pursuant to the statutes cited in
Paragraph 4.
5.
To the extent the allegations in Paragraph 5 state legal conclusions, no
response is required. To the extent a response is required, Galleon admits that its headquarters
are located in New York, New York, but lacks knowledge or information sufficient to form a
belief as to the truth of the other allegations in Paragraph 5, except admits that Plaintiff purports
to base venue on the statutes cited in Paragraph 5.
6.
Galleon admits the allegations in the first and second sentences of
Paragraph 6. Galleon admits that it is the investment manager for several hedge funds,
including, among others, Galleon Technology Offshore, Ltd., Galleon Diversified Fund, Ltd.,
Galleon Emerging Technology Offshore, Ltd., Galleon Buccaneer’s Offshore, Ltd., Galleon
Explorers Offshore, Ltd., and Galleon Strategic Fund, Ltd.
7.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in the first, third, and fourth sentences of Paragraph 7. Galleon admits
that Raj Rajaratnam (“Rajaratnam”) is a managing member of Galleon Management, L.L.C. The
general partner of Galleon is Galleon Management, L.L.C.
8.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 8.
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9.
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Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 9, except admits that Ambit Ltd., an entity in which Mr.
Kumar has or had a beneficial interest, has one or more investment interests in funds managed by
Galleon.
10.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 10.
11.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 11.
12.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 12.
13.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 13.
14.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 14, except admits that Khan was previously employed by
or associated with Galleon or one of its affiliates.
15.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 15.
16.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 16.
17.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 17.
18.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 18.
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19.
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Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 19.
20.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 20.
21.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 21.
22.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 22.
23.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 23, except admits that Akami provides services for
facilitating the delivery of content and applications over the Internet and that Akami’s stock
trades on the Nasdaq under the symbol “AKAM.”
24.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 24, except admits that AMD is a semiconductor
company headquartered in Sunnyvale, California and that AMD’s stock trades on the NYSE
under the symbol “AMD.”
25.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 25, except admits that Atheros is a developer of
semiconductor systems for wireless and other network communication products, and that
Atheros’s stock trades on the Nasdaq under the symbol “ATHR.”
26.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 26, except admits that on October 25, 2006, AMD
completed an approximately $5.4 billion acquisition of ATI, that ATI designed and
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manufactured 3D graphics, PC platform technologies and digital media silicon solutions, and that
ATI’s stock traded on the Nasdaq under the symbol “ATYT.”
27.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 27, except admits that Clearwire builds and operates
wireless broadband networks in the United States and abroad, that it is headquartered in
Kirkland, Washington, and that Clearwire’s stock trades on the Nasdaq under the symbol
“CLWR.” Galleon admits that Intel or an Intel subsidiary provided financing for Clearwire’s
joint venture with Sprint.
28.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 28, except admits that eBay provides online
marketplaces for the sale of goods and services as well as online payment services and online
communication offerings to individuals and businesses, and that eBay’s stock is traded on the
Nasdaq under the symbol “EBAY.”
29.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 29, except admits that Far was previously employed by
or associated with Galleon or one of its affiliates.
30.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 30.
31.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 31, except admits that Google hosts an internet search
engine, that it is headquartered in Mountain View, California, and that Google’s stock trades on
the Nasdaq under the symbol “GOOG.”
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Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 32, except admits that Hilton is an international hotel
chain, that Hilton was taken private by the Blackstone Group, and that Hilton ceased trading on
the NYSE, but formerly traded under the symbol “HLT.”
33.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 33, except admits IBM is a computer technology and IT
consulting firm and that IBM’s stock trades on the NYSE under the symbol “IBM.”
34.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 34, except admits that Intel is a microprocessor
manufacturer headquartered in Santa Clara, California, that Intel or an Intel subsidiary invested
$1 billion in a joint venture in which Clearwire and Sprint agreed to combine their wireless
broadband or WiMax, businesses, and that Intel’s stock trades on the Nasdaq under the symbol
“INTC.”
35.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 35, except admits that Kronos makes workforce
management software for businesses, that Kronos was acquired by Hellman & Friedman, and
that Kronos stock traded on the Nasdaq under the symbol “KRON.”
36.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 36.
37.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 37.
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38.
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Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 38, except admits that McKinsey is a global management
consulting firm that advises on issues of strategy, organization, technology, and operations.
39.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 39, except admits that Moody’s is a rating agency that
performs research and analysis on borrower credit-worthiness, and that Moody’s is a registered
Nationally Recognized Statistical Rating Organization.
40.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 40, except admits that PeopleSupport was a business
process outsourcing provider offering customer management, transcription, captioning and other
services, that it merged with Aegis BPO Services Ltd., and that PeopleSupport’s stock traded on
the Nasdaq under the symbol “PSPT.”
41.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 41, except admits that Polycom produces applications
for voice, video, and data networking and that Polycom’s stock trades on the Nasdaq under the
symbol “PLCM.”
42.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 42.
43.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 43, except admits that SUN provides network computing
infrastructure, that it is headquartered in Santa Clara, California, that SUN’s stock trades on the
Nasdaq under the symbol “JAVA” and that Oracle Corporation announced that it had entered
into a definitive merger agreement pursuant to which it would acquire SUN.
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44.
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Galleon admits that Khan worked for a time at Galleon. Galleon lacks
knowledge or information sufficient to form a belief as to the truth of the allegation that Khan
was facing financial difficulties. Galleon denies the remaining allegations in Paragraph 44.
45.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 45.
46.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 46.
47.
The allegations in Paragraph 47 are based on public information, and
Galleon refers to such information for an accurate statement of its contents.
48.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 48.
49.
Galleon denies the allegations in the second and third sentences of
Paragraph 49. Galleon admits that it or its affiliates traded in Polycom securities and refers to its
trading records produced in this Action for an accurate statement of such trading. Galleon denies
that it or any of its employees or affiliates traded or profited on the basis of material, non-public
information and denies the allegations in Paragraph 49 to the extent they contend otherwise.
Galleon lacks knowledge or information sufficient to form a belief as to the truth of the
remaining allegations in Paragraph 49.
50.
Galleon admits that it or its affiliates traded in Polycom securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
51.
Galleon admits that it or its affiliates traded in Polycom securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
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material, non-public information and denies the allegations in Paragraph 51 to the extent they
contend otherwise.
52.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 52.
53.
Galleon denies the allegations in Paragraph 53, except that it lacks
knowledge or information sufficient to form a belief as to the truth of the allegations in the first
sentence.
54.
Galleon admits that it or its affiliates traded in Polycom securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
material, non-public information and denies the allegations in Paragraph 54 to the extent they
contend otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the
truth of the remaining allegations in Paragraph 54.
55.
To the extent the allegations in Paragraph 55 are based on public
information, Galleon refers to such information for an accurate statement of its contents.
Galleon admits that it or its affiliates traded in Polycom securities and refers to its trading records
produced in this Action for an accurate statement of such trading. Galleon denies that it or any
of its employees or affiliates traded or profited on the basis of material, non-public information
and denies the allegations in Paragraph 55 to the extent they contend otherwise. Galleon lacks
knowledge or information sufficient to form a belief as to the truth of the remaining allegations
in Paragraph 55.
56.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 56.
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57.
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Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 57.
58.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 58, except that Galleon denies that it or any of its
employees or affiliates traded or profited on the basis of material, non-public information and
denies the allegations in Paragraph 58 to the extent they contend otherwise.
59.
Galleon admits that it or its affiliates traded in Hilton securities and refers
to its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 59 to the extent they contend
otherwise. Galleon denies the remaining allegations in Paragraph 59 and refers to the offering
materials for the funds it advises produced in this Action for a correct statement of their
purposes.
60.
The allegations in Paragraph 60 are based on public information, and
Galleon refers to such information for an accurate statement of its contents.
61.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 61.
62.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 62.
63.
Galleon admits that it or its affiliates traded in Hilton securities and refers
to its trading records produced in this Action for an accurate statement of such trading.
64.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 64.
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65.
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Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 65.
66.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 66.
67.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 67.
68.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 68.
69.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 69.
70.
Galleon denies the allegations in Paragraph 70.
71.
Galleon admits that it or its affiliates traded in Google securities and refers
to its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 71 to the extent they contend
otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the truth of
the remaining allegations in Paragraph 71.
72.
The allegations in Paragraph 72 are based on public information, and
Galleon refers to such information for an accurate statement of its contents.
73.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 73.
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74.
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Galleon admits that it or its affiliates traded in Google securities and refers
to its trading records produced in this Action for an accurate statement of such trading. Galleon
denies the remaining allegations in Paragraph 74.
75.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 75.
76.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 76.
77.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 77.
78.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 78.
79.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 79.
80.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 80.
81.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 81.
82.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 82.
83.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 83.
84.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 84.
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Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 85.
86.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 86.
87.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 87.
88.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 88.
89.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 89.
90.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 90.
91.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 91.
92.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 92.
93.
Galleon denies the allegations in the first sentence of Paragraph 93.
Galleon lacks knowledge or information sufficient to form a belief as to the truth of the
remaining allegations in Paragraph 93.
94.
Galleon denies the allegations in Paragraph 94.
95.
Galleon admits that it or its affiliates traded in Intel securities and refers to
its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, non-
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public information and denies the allegations in Paragraph 95 to the extent they contend
otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the truth of
the remaining allegations in Paragraph 95.
96.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in the first and third sentences of Paragraph 96. Galleon admits that it
or its affiliates traded in Intel securities and refers to its trading records produced in this Action
for an accurate statement of such trading. Galleon denies that it or any of its employees or
affiliates traded or profited on the basis of material, non-public information and denies the
allegations in Paragraph 94 to the extent they contend otherwise. Galleon lacks knowledge or
information sufficient to form a belief as to the truth of the remaining allegations in Paragraph
96.
97.
The allegations in Paragraph 97 are based on public information, and
Galleon refers to such information for an accurate statement of its contents.
98.
To the extent the allegations in Paragraph 98 are based on public
information, Galleon refers to such information for an accurate statement of its contents.
Galleon lacks knowledge or information sufficient to form a belief as to the truth of the
allegations in the second sentence. Galleon admits that it or its affiliates traded in Intel securities
and refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
material, non-public information and denies the allegations in Paragraph 98 to the extent they
contend otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the
truth of the remaining allegations in Paragraph 98.
14
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99.
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Filed 02/16/2010
Page 15 of 28
Galleon denies the allegations in the first sentence of Paragraph 99.
Galleon admits that it or its affiliates traded in Intel securities and refers to its trading records
produced in this Action for an accurate statement of such trading. Galleon denies that it or any
of its employees or affiliates traded or profited on the basis of material, non-public information
and denies the allegations in Paragraph 99 to the extent they contend otherwise. Galleon lacks
knowledge or information sufficient to form a belief as to the truth of the remaining allegations
in Paragraph 99.
100.
Galleon admits that it or its affiliates traded in Intel securities and refers to
its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 100 to the extent they contend
otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the truth of
the remaining allegations in Paragraph 100.
101.
Galleon admits that it or its affiliates traded in Intel securities and refers to
its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 101 to the extent they contend
otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the truth of
the remaining allegations in Paragraph 101.
102.
Galleon admits that it or its affiliates traded in Intel securities and refers to
its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 102 to the extent they contend
15
Case 1:09-cv-08811-JSR
Document 146
Filed 02/16/2010
Page 16 of 28
otherwise. To the extent the allegations in Paragraph 102 are based on public information,
Galleon refers to such information for an accurate statement of its contents.
103.
Galleon admits that it or its affiliates traded in Intel securities and refers to
its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 103 to the extent they contend
otherwise.
104.
Galleon admits that it or its affiliates traded in Intel securities and refers to
its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 104 to the extent they contend
otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the truth of
the remaining allegations in Paragraph 104.
105.
Galleon admits that it or its affiliates traded in Intel securities and refers to
its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 105 to the extent they contend
otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the truth of
the remaining allegations in Paragraph 105.
106.
Galleon denies the allegations in Paragraph 106.
107.
The allegations in Paragraph 107 are based on public information, and
Galleon refers to such information for an accurate statement of its contents.
16
Case 1:09-cv-08811-JSR
108.
Document 146
Filed 02/16/2010
Page 17 of 28
Galleon admits that it or its affiliates traded in Clearwire securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
material, non-public information and denies the allegations in Paragraph 108 to the extent they
contend otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the
truth of the remaining allegations in Paragraph 108.
109.
Galleon admits that it or its affiliates traded in Clearwire securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
material, non-public information and denies the allegations in Paragraph 109 to the extent they
contend otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the
truth of the remaining allegations in Paragraph 109.
110.
Galleon admits that it or its affiliates traded in Clearwire securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
material, non-public information and denies the allegations in Paragraph 110 to the extent they
contend otherwise. To the extent the allegations in Paragraph 110 are based on public
information, Galleon refers to such information for an accurate statement of its contents.
Galleon lacks knowledge or information sufficient to form a belief as to the truth of the
remaining allegations in Paragraph 110.
111.
Galleon admits that it or its affiliates traded in Clearwire securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
17
Case 1:09-cv-08811-JSR
Document 146
Filed 02/16/2010
Page 18 of 28
material, non-public information and denies the allegations in Paragraph 111 to the extent they
contend otherwise. To the extent the allegations in Paragraph 111 are based on public
information, Galleon refers to such information for an accurate statement of its contents.
Galleon lacks knowledge or information sufficient to form a belief as to the truth of the
remaining allegations in Paragraph 111.
112.
Galleon admits that it or its affiliates traded in Clearwire securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
material, non-public information and denies the allegations in Paragraph 112 to the extent they
contend otherwise. To the extent the allegations in Paragraph 112 are based on public
information, Galleon refers to such information for an accurate statement of its contents.
Galleon lacks knowledge or information sufficient to form a belief as to the truth of the
remaining allegations in Paragraph 112.
113.
Galleon denies the allegations in Paragraph 113.
114.
Galleon denies the allegations in Paragraph 114.
115.
Galleon admits that it and certain of its affiliates held at certain times an
aggregate direct or indirect equity ownership stake in PeopleSupport common stock of
approximately 25%, and that at certain times a person affiliated or associated with Galleon was a
member of PeopleSupport’s board of directors. Galleon denies that it or any of its employees or
affiliates traded or profited on the basis of material, non-public information and denies the
allegations in Paragraph 115 to the extent they contend otherwise. Furthermore, with respect to
the PeopleSupport director associated with Galleon, Galleon adhered to PeopleSupport’s trading
18
Case 1:09-cv-08811-JSR
Document 146
Filed 02/16/2010
Page 19 of 28
policies, applicable requirements of Section 16 of the Securities Exchange Act of 1934, as well
as Galleon’s own policies and other restrictions associated with such holdings.
116.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 116. Galleon denies that it or any of its employees or
affiliates traded or profited on the basis of material, non-public information and denies the
allegations in Paragraph 116 to the extent they contend otherwise.
117.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 117.
118.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 118.
119.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 119.
120.
The allegations in Paragraph 120 are based on public information, and
Galleon refers to such information for an accurate statement of its contents.
121.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 121.
122.
Galleon denies the allegations in Paragraph 122.
123.
Galleon admits that it or its affiliates traded in Akamai securities and
refers to its trading records produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
material, non-public information and denies the allegations in Paragraph 123 to the extent they
contend otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the
truth of the remaining allegations in Paragraph 123.
19
Case 1:09-cv-08811-JSR
124.
Document 146
Filed 02/16/2010
Page 20 of 28
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 124.
125.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 125.
126.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 126.
127.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 127.
128.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 128.
129.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 129.
130.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 130.
131.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 131.
132.
Galleon denies the allegations in Paragraph 132.
133.
Galleon denies the allegations in Paragraph 133.
134.
Galleon admits that it or its affiliates traded in ATI securities and refers to
its trading records for an accurate statement of such trading. Galleon denies that it or any of its
employees or affiliates traded or profited on the basis of material, non-public information and
denies the allegations in Paragraph 134 to the extent they contend otherwise. Galleon lacks
20
Case 1:09-cv-08811-JSR
Document 146
Filed 02/16/2010
Page 21 of 28
knowledge or information sufficient to form a belief as to the truth of the remaining allegations
in Paragraph 134.
135.
Galleon admits that it or its affiliates traded in ATI securities and refers to
its trading records to be produced in this Action for an accurate statement of such trading.
Galleon denies that it or any of its employees or affiliates traded or profited on the basis of
material, non-public information and denies the allegations in Paragraph 135 to the extent they
contend otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the
truth of the remaining allegations in Paragraph 135.
136.
Galleon denies the allegations in Paragraph 136.
137.
Galleon denies the allegations in Paragraph 137.
138.
Galleon denies the allegations in Paragraph 138.
139.
The allegations in Paragraph 139 are based on public information, and
Galleon refers to such information for an accurate statement of its contents.
140.
Galleon admits that it or its affiliates traded in AMD securities and refers
to its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 140 to the extent they contend
otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the truth of
the remaining allegations in Paragraph 140.
141.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 141.
21
Case 1:09-cv-08811-JSR
142.
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Page 22 of 28
Galleon denies the allegations in the first sentence of Paragraph 142.
Galleon lacks knowledge or information sufficient to form a belief as to the truth of the
remaining allegations in Paragraph 142.
143.
Galleon denies the allegations in the second and fourth sentences of
Paragraph 143. Galleon lacks knowledge or information sufficient to form a belief as to the truth
of the remaining allegations in Paragraph 143.
144.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 144.
145.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 145.
146.
Galleon admits that it or its affiliates traded in AMD securities and refers
to its trading records produced in this Action for an accurate statement of such trading. Galleon
denies that it or any of its employees or affiliates traded or profited on the basis of material, nonpublic information and denies the allegations in Paragraph 146 to the extent they contend
otherwise. Galleon lacks knowledge or information sufficient to form a belief as to the truth of
the remaining allegations in Paragraph 146.
147.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 147.
148.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 148.
149.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 149.
22
Case 1:09-cv-08811-JSR
150.
Document 146
Filed 02/16/2010
Page 23 of 28
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 150.
151.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 151.
152.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 152.
153.
The allegations in Paragraph 153 are based on public information, and
Galleon refers to such information for an accurate statement of its contents. To the extent a
response is required, Galleon lacks knowledge or information sufficient to form a belief as to the
truth of the allegations in Paragraph 153.
154.
Galleon admits that it or its affiliates traded in eBay securities and refers
to its trading records for an accurate statement of such trading. Galleon denies that it or any of
its employees or affiliates traded or profited on the basis of material, non-public information and
denies the allegations in Paragraph 154 to the extent they contend otherwise. Galleon lacks
knowledge or information sufficient to form a belief as to the truth of the remaining allegations
in Paragraph 154.
155.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 155.
156.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 156.
157.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 157.
23
Case 1:09-cv-08811-JSR
158.
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Page 24 of 28
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 158.
159.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 159.
160.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 160.
161.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 161.
162.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 162.
163.
Galleon lacks knowledge or information sufficient to form a belief as to
the truth of the allegations in Paragraph 163, except that Galleon admits that Atheros issued its
Q4 2008 earnings release on February 2, 2009.
164.
In response to Paragraph 164, Galleon repeats and re-alleges each of the
foregoing responses as if set forth fully herein.
165.
To the extent the allegations in Paragraph 165 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 165.
166.
To the extent the allegations in Paragraph 166 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 166.
24
Case 1:09-cv-08811-JSR
167.
Document 146
Filed 02/16/2010
Page 25 of 28
To the extent the allegations in Paragraph 167 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 167.
168.
To the extent the allegations in Paragraph 168 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 168.
169.
To the extent the allegations in Paragraph 169 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 169.
170.
To the extent the allegations in Paragraph 170 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 170.
171.
To the extent the allegations in Paragraph 171 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 171.
172.
To the extent the allegations in Paragraph 172 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 172.
173.
To the extent the allegations in Paragraph 173 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 173.
25
Case 1:09-cv-08811-JSR
174.
Document 146
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Page 26 of 28
To the extent the allegations in Paragraph 174 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 174.
175.
In response to Paragraph 175, Galleon repeats and re-alleges each of the
foregoing responses as if set forth fully herein.
176.
To the extent the allegations in Paragraph 176 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 176.
177.
To the extent the allegations in Paragraph 177 state legal conclusions, no
response is required. To the extent a response is required, Galleon denies the allegations in
Paragraph 177.
The Relief Sought by Plaintiff does not contain allegations of fact or law that
require a response from Galleon. However, to the extent a response is required, Galleon denies
the allegations in the Relief Sought and denies that the Relief Sought by Plaintiff is appropriate
or available.
To the extent any allegation in the Second Amended Complaint is not admitted
herein, it is denied.
AFFIRMATIVE DEFENSES
Galleon asserts the following affirmative defenses without assuming the burden of
proof, persuasion, or going forward as to any such defenses or issues that would otherwise rest
on Plaintiff. Galleon reserves the right to amend its pleadings, and to assert additional or
different defenses, based upon information or evidence developed in discovery or otherwise.
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Case 1:09-cv-08811-JSR
1.
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Page 27 of 28
The Second Amended Complaint fails to state a claim upon which relief
can be granted.
2.
The Second Amended Complaint fails to allege fraud with particularity.
3.
The Second Amended Complaint fails to plead scienter with particularity.
4.
Plaintiff’s claims are barred in whole or in part by the applicable statute of
5.
Plaintiff’s claims are barred in whole or in part by laches.
6.
Equitable relief requested by Plaintiff is unavailable, either in whole or in
limitations.
part, because the alleged conduct occurred wholly in the past and is unlikely to be repeated.
7.
Galleon acted at all times in good faith, and without knowledge of any
supposed wrongdoing.
8.
At all relevant times, Galleon maintained and applied in good faith an
appropriate compliance program intended to ensure compliance by its employees and affiliates
with all laws, rules, and regulations applicable to its business.
27
Case 1:09-cv-08811-JSR
Dated:
Document 146
Filed 02/16/2010
Page 28 of 28
February 16, 2010
New York, New York
SHEARMAN
& STERLING LLP
By:
/s/ Adam S. Hakki
Adam S. Hakki
Fishbein
A. Nathanson
Stephen
John
599
New
(212)
(212)
Lexington Avenue
York, NY 10022-6069
848-4000
848-7179 (facsimile)
Attorneys for Galleon Management, L.P.
28
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([KLELW $
Redacted
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]]>
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