USSEC v. Patel, et al.

2008 DNH 039
CourtDistrict Court, D. New Hampshire
DecidedFebruary 19, 2008
Docket07-CV-039-SM
StatusPublished

This text of 2008 DNH 039 (USSEC v. Patel, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USSEC v. Patel, et al., 2008 DNH 039 (D.N.H. 2008).

Opinion

USSEC v. Patel, et a l . 07-CV-039-SM 02/19/08 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Securities and Exchange Commission, Plaintiff

v. Civil No. 07-cv-39-SM Opinion No. 2008 DNH 039 Pivush G. Patel; David J. Kirkpatrick; Eric Jaeger; Bruce D. Kav; Robert J. Gagalis; Robert G. Barber, Jr.; Lawrence Collins; Michael A. Skubisz; Jerry A. Shanahan; and Hor Chong (David) Boev, Defendants

O R D E R

The Securities and Exchange Commission ("SEC") has sued in

eight counts, seeking injunctive relief under 15 U.S.C. § 77t(b)

and 15 U.S.C. §§ 78u(d) & (e) for various alleged violations of

the Securities Act of 1933 and the Securities Exchange Act of

1934. Specifically, the SEC asserts violations of: 15 U.S.C.

§ 77q(a)(1) by all defendants (Count I, captioned "fraud"); 15

U.S.C. §§ 77q(a)(2) & (3) by all defendants (Count II, captioned

"fraud"); 15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5 by all

defendants (Count III, captioned "fraud"); 15 U.S.C. § 78m(b)(5)

and 17 C.F.R. § 240.13b2-l by all defendants (Count IV, captioned

"falsified books and records"); 17 C.F.R. § 240.13b2-2 by all

defendants (Count V, captioned "deceit of auditors"); 15 U.S.C. § 78m(a) and 17 C.F.R. §§ 240.12b-20, 240.13a-l, 240.13a-ll &

240.13a-13 by all defendants (Count VI, captioned "false SEC

filings"); 15 U.S.C. § 78m(b)(2) by all defendants (Count VII,

captioned "false books and records"); and 15 U.S.C. § 78m(b)(2)

by some defendants (Count VIII, captioned "inadequate accounting

controls"). Before the court is Jerry A. Shanahan's motion for a

more definite statement. For the reasons given, Shanahan's

motion is denied.

The complaint alleges that from March 2000 through December

2001, various employees, officers, and directors of Cabletron

Systems, Inc. ("Cabletron") or its former subsidiaries, Enterasys

Networks, Inc. ("Enterasys") and Aprisma Management Technologies,

Inc. ("Aprisma") participated in a company-wide scheme to falsely

inflate the apparent revenues of Cabletron and Enterasys for the

purpose of convincing investors that Enterasys was a viable

independent company with consistently strong revenue growth.

Shanahan served as Cabletron's Vice President of International

Operations from February 2000 to September 2000, Cabletron's Vice

President of Operations and Quality from September 2000 to March

2001, and Enterasys's Chief Operating Officer from March 2001

until May 2002.

2 More specifically, the SEC alleges that the defendants

improperly recognized revenue, reported that improperly

recognized revenue in SEC filings and press releases, and

misrepresented material information concerning improper revenue

recognition to outside auditors, or concealed material

information from them. According to the SEC, Enterasys

improperly recognized revenue of at least $48 million, and, in

turn, overstated its earnings and understated its operating

losses. Based upon that false financial picture, Enterasys

successfully launched itself as an independent public company on

August 6, 2001.

The SEC alleges that the improper revenue recognition took

several forms: (1) undisclosed side agreements with purchasers

that significantly qualified apparent sales transactions by, for

example, providing buyers with full return, exchange, or

cancellation rights; (2) investments in privately held companies

that agreed to use the invested funds to purchase Enterasys and

Aprisma products; and (3) so-called "three-corner deals" that

involved placing another company between Enterasys and an

investee company, to disguise purchases of Enterasys products

made with funds invested in the purchasing company by Enterasys.

The complaint discusses in greater detail twelve separate

contingent sales transactions or investment deals (Compl. 63-

3 137) and describes in lesser detail seventeen additional sales

transactions (Compl. 138-55) from which the SEC claims

Enterasys improperly recognized revenue. Shanahan is included,

by name, in the factual allegations related to: (1) a side

agreement between Enterasys and Tech Data Canada, Inc., which

resulted in the improper recognition of $3 million in revenue in

the second quarter of Transition Year 2001 (Compl. 91-96); (2)

an improper side agreement between Enterasys and Societe General

Cowen (Compl. 97-103); (3) a side agreement with GovStreetUSA,

LLC, that resulted in the improper recognition of $2.6 million in

revenue, over the course of three quarters, that was reported in

one SEC form 10-K and three SEC 10-Q forms (Compl. 104-10);

and (4) improper recognition of $500,000 in revenue from sales to

Accton Technology Corp. during the first quarter of Transition

Year 2001 (Compl. 5 148).

The complaint further alleges that Shanahan and others

participated in numerous weekly conference calls in which "the

participants openly discussed the purpose of three corner deals:

to conceal from Enterasys's outside auditor the connection

between investments and purchases, given that the poor financial

condition of investee companies could lead the outside auditor to

conclude that the related revenue did not comport with GAAP"

(Compl. 5 158), and that Shanahan "and others worked together to

4 close more than $20 million in investment-related sales during

the final week of the [second] quarter [of Transition Year 2001],

many of which were structured as three corner deals to conceal

the precarious financial condition of the investee company from

Enterasys's outside auditor" (Compl. 5 162).

The SEC asserts that any public statement of earnings that

included improperly recognized revenue was materially false and

that Enterasys made such statements in: (1) one SEC 10-K form;

(2) six SEC 10-Q forms; (3) 3 SEC 8-K forms; (4) fourteen

representation letters; and (5) seven press releases. (Compl. 5

36.) The complaint goes on to specify the alleged falsity of

each of the identified SEC filings, based upon its incorporation

of improperly recognized revenue. (Compl. 37-53.) The

complaint provides similar specifications for the press releases.

(Compl. M 171-87.)

Shanahan moves the court to order the SEC to provide a more

definite statement of the claims against him. According to

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