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Stanford University Law School - Securities Class Action Clearinghouse
MILBERG WEISS BERSHAD
  HYNES & LERACH LLP
WILLIAM S. LERACH  (68581)
ALAN SCHULMAN (128661)
MARK SOLOMON (151949)
600 West Broadway, Suite 1800
San Diego, CA  92101
Telephone:  619/231-1058
     - and -
KIMBERLY C. EPSTEIN (169012)
222 Kearny Street, 10th Floor 
San Francisco, CA  94108
Telephone:  415/288-4545

WEISS & YOURMAN
JOSEPH H. WEISS
JACK I. ZWICK
551 Fifth Avenue
Suite 1600
New York, NY  10176
Telephone:  212/682-3025
     - and -
KEVIN J. YOURMAN (147159)             BERNSTEIN LIEBHARD & LIFSHITZ
10940 Wilshire Blvd.                  MEL E. LIFSHITZ
24th Floor                            274 Madison Avenue
Los Angeles, CA  90024                New York, NY  10016
Telephone:  310/208-2800              Telephone:  212/779-1414

Attorneys for Plaintiffs


                  UNITED STATES DISTRICT COURT

                 NORTHERN DISTRICT OF CALIFORNIA

                        SAN JOSE DIVISION


BROOKE GRAUBART, MORRIS RUBIN and       ) No. C-97-20265
SOLOMON EISENBERG, On Behalf of         )
Themselves and All Others Similarly     ) CLASS ACTION
Situated,                               )
                                        )
                    Plaintiffs,         ) COMPLAINT FOR VIOLATION
                                        ) OF THE FEDERAL
     vs.                                ) SECURITIES LAWS
                                        )
INSIGNIA SOLUTIONS PLC, INSIGNIA        )
SOLUTIONS INC., ROBERT P. LEE, ROGER D. )
FRIEDBERGER, PAUL R. GRIFFITHS, JOHN R. )
JOHNSTON, RICHARD M. NOLING, NICHOLAS   )
A. SAMUEL and DAVID L. GIBBS,           )
                                        )
                    Defendants.         ) Plaintiffs Demand A
_______________________________________ ) Trial By Jury




                   INTRODUCTION AND OVERVIEW      1.   This is a securities class action on behalf of all purchasers of the American Depository Shares ("ADS") of Insignia Solutions plc ("Insignia" or the "Company") between November 14, 1995 and February 26, 1997 (the "Class Period"), seeking to remedy violations of the federal securities laws committed by the Company and certain of its insiders.      2.   In November 1995, as part of the scheme complained of herein, the defendants collectively sold 3.6 million ADSs to the public ("IPO" or the "Offering") at an artificially inflated price of $12 per share, including some $20 million of ADSs sold by Insignia insiders.  Thereafter, defendants artificially inflated the price of Insignia's ADSs by making false and misleading statements to securities analysts and others and by falsifying the company's financial statements for the first three fiscal quarters of 1996.  During that time, the defendants made it their practice to improperly recognize revenue from contingent sales in order to meet their misleading forecasts.      3.   Defendants misleadingly represented in the Registration Statement and Prospectus disseminated in November 1995 in connection with the offering and via additional statements directed at the investing public thereafter that Insignia: (i) competed favorably in the cross-platform compatibility software market; (ii) had an effective direct sales force; (iii) had successfully introduced new computer software products (SoftWindows 2.0) for both the UNIX and Apple/Macintosh operating systems; (iv) had a very strong third quarter of 1995 with revenues jumping to $16.3 million; (v) anticipated strong growth in the fourth quarter of COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 1 -
1995 with revenues increasing to $18 million; (vi) projected revenues of $80-81 million for 1996; and (vii) projected 1996 earnings per share of $0.80.      4.   In truth, however, defendants knew that the Company was unable to make the sales necessary to meet their forecasts.  In early January 1996 they experienced, first-hand, the market's reaction to the news that their forecasts for Insignia's first quarter as a public company were woefully inaccurate.  On January 2, 1996, barely six weeks after the offering, the Company stunned the market by revealing that revenues had shrunk rather than grown in the quarter ended December 31, 1995 because of disappointing sales.  The disclosure caused Insignia's ADS price to collapse to $5-3/4 per share from $13-1/4 per share; a 56% one-day drop and a 74% drop from its December high of $22 per share.      5.   After the disastrous announcement of January 2, 1996, defendants knew that the price of Insignia's ADSs had to be supported by the issuance of even more positive projections and the concomitant reporting of revenues meeting those projections. Unable to do so if Insignia's revenues were accurately projected and reported, defendants continued their deceitful course of conduct by misrepresenting the true status of the Company's sales, earnings and assets.  Accordingly, through the use of securities analysts, Insignia told the market to expect 1996 revenues of $14.5 million, $16.6 million, $17.7 million and $19.3 million for the first, second, third and fourth quarters of 1996, respectively, and earnings per share of $0.06, $0.12, $0.14 $0.23 for the first, second, third and fourth quarters of 1996, respectively.  During these periods, Insignia continued to offer incentives and absolute COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 2 -
rights of return to its customers including Merisel, TechData and Ingram Micro.  Insignia's improper revenue recognition caused the Company to materially misstate its earnings for the first three fiscal quarters of 1996 and record them in violation of Generally Accepted Accounting Principles ("GAAP").  Defendants' false financial statements were contained in the 1996 quarterly Form 10-Q's filed by Insignia with the Securities Exchange Commission ("SEC").  By improperly recognizing revenue for Insignia's contingent sales, defendants materially inflated its revenue, earnings and assets -- resulting in the continued artificial inflation of the Company's share price.      6.   Finally, on February 27, 1997, the Company announced that, due to accounting "irregularities" involving certain sales contracts and reseller inventories that resulted in improper recognition of revenue in violation of GAAP, the first and second quarter 1996 revenues and net income must be restated.  The Company expressly admitted to "irregularities in the reporting of sales contracts and reseller inventories."  As a result, Insignia's reported profit of $749,000 for the first quarter of 1996 was restated as a loss of $225,000.  The previous reported earnings per share of $0.06 was revised to a loss of $0.02 per share. Insignia's reported profit of $1.5 million for the second quarter of 1996 was slashed to a mere $569, 000.  The previous reported earnings per share of $0.11 was revised to just $0.04. Insignia's previous reported revenues of $39.5 million for the nine months ended September 30, 1996, was reduced to $37.1 million.  As reported by UBS Securities, "[a]side from weak fundamentals, the company must now deal with additional operational problems and COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 3 -
another blow to management's credibility."  Upon these revelations, the price of Insignia's ADSs dropped from $3-7/8 to $2-1/2 per share.      7.   Defendants' conduct represents a flagrant abuse of the federal securities laws which were designed to protect investors and is an example of how sophisticated corporate insiders and financiers can mislead the investing public.  Utilizing the offering, the defendants (other than Richard M. Noling who joined the company subsequently) sold over $43 million of Insignia securities to the public at grossly inflated prices when they knew Insignia's business was in trouble, performing poorly, and declining instead of growing and prospering as the defendants represented in connection with the Offering.  As a result, and to stave off the disclosure of the truth, all of the defendants then continued the fraudulent scheme throughout the Class Period, the truth being revealed.  Only after a former employee sued the Company for being unfairly singled out as a "scapegoat" blamed for the defendants' unlawful revenue recognition practices and, thereafter, the Company's ultimate admission that, owing to improper sales reporting, it was forced to restate its revenues for the first and second quarters of 1996.      8.   As set forth more fully below, defendants' positive statements during the Class Period about Insignia's business, products, competitive position and prospects as well as the Company's financial statements for the first and second quarters of 1996 were false and misleading when made and failed to disclose material adverse information known to or recklessly disregarded by defendants. COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 4 -
     9.   The charts below demonstrate the price action of Insignia's ADSs during the Class Period and the collapse of Insignia's ADS price as the previously concealed facts about Insignia's business emerged, and the performance of Insignia's ADSs compared to indices of similar companies, which shows that the action of Insignia's ADSs was due largely to company-specific events and not market forces:                      Insignia Solutions PLC              November 14, 1995 - February 28, 1997                        Daily Stock Prices
Insignia Chart 1

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 5 -



                     Insignia Solutions PLC     vs. H&Q Software Products Index and S&P Software Index              November 14, 1995 - February 28, 1997
Insignia Chart 2

                     JURISDICTION AND VENUE

     10.  Jurisdiction exists pursuant to §27 of the Securities

Exchange Act of 1934 ("Exchange Act"), 15 U.S.C. §78aa, and 28

U.S.C. §1331.  The claims asserted arise under §§10(B) and 20(a) of

the Exchange Act, 15 U.S.C. §§78j(b) and 78t(a), and Rule 10b-5,

promulgated thereunder.

     11.  (a)  Venue is proper in this District pursuant to §27 of

the Exchange Act and 28 U.S.C. §1391(b).  Many of the acts giving

rise to the violations complained of occurred in this District; and

          (b)  Assignment of this action to the San Jose Division

is appropriate as a substantial part of the events or omissions

identified herein occurred in Santa Clara County.

     12.  Defendants used the instrumentalities of interstate

commerce, the U.S. mails and the facilities of the national

securities markets.


COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 6 -



                    CLASS ACTION ALLEGATIONS      13.  Plaintiffs bring this action as a class action pursuant to Federal Rule of Civil Procedure 23(a) and (b)(3) on behalf of all persons who purchased or otherwise acquired Insignia ADSs from November 14, 1995 through February 26, 1997 (the "Class"),  excluding the defendants, members of their families and any entity in which a defendant has an interest.      14.  The members of the Class are so numerous that joinder of all members is impracticable.  The disposition of their claims in a class action will provide substantial benefits to the parties and the Court.  During the Class Period, Insignia had more than 11 million ADSs outstanding, owned by at least hundreds of shareholders.      15.  The questions of law and fact are common to the members of the Class and predominate over questions which may affect individual Class members, including the following:           (a)  Whether defendants omitted and/or misrepresented material facts;           (b)  Whether defendants knew or recklessly disregarded the fact that the statements made by them were false and misleading;           (c)  Whether the price of Insignia ADSs was artificially inflated during the Class Period;           (d)  The extent of damage sustained by Class members and the appropriate measure of damages; and           (e)  Whether the federal securities laws were violated by  defendants. COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 7 -
     16.  Plaintiffs' claims are typical of those of the Class because plaintiffs and the Class sustained damages from defendants' wrongful conduct uniformly directed at the Class.      17.  Plaintiffs will adequately protect the interests of the Class.  They have retained counsel who are experienced in class action securities litigation.  Plaintiffs have no interests which conflict with those of the Class.      18.  A class action is superior to other available methods for the fair and efficient adjudication of this controversy.      19.  The prosecution of separate actions by individual Class members would create a risk of inconsistent and varying adjudications.                            THE PARTIES      20.  (a)  Plaintiff Brooke Graubart purchased 1,000 Insignia ADSs on May 10, 1996, 1,000 Insignia ADSs on May 14, 1996, 2,000 Insignia ADSs on May 29, 1996, 1,000 Insignia ADSs on June 11, 1996, and 3,000 Insignia ADSs on June 17, 1996, and was damaged thereby.           (b)  Plaintiff Morris Rubin purchased 1,000 Insignia ADSs on May 30, 1996, and was damaged thereby.           (c)  Plaintiff Solomon Eisenberg purchased 3,600 Insignia ADSs on January 3, 1996, and 2,000 Insignia ADSs on May 28, 1996, and was damaged thereby.      21.  (a)  Defendant Insignia Solutions plc, is an English public limited corporation, which operates through its subsidiary, defendant Insignia solutions Inc., a Delaware Corporation, both of which have their principal executive offices and place of business in Mountain View, California (collectively "Insignia") - Insignia's COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 8 -
ADSs are traded in an efficient market on the NASDAQ National Market System.           (b)  Insignia develops, markets and supports cross- platform compatibility software solutions.  SoftWindows, Insignia's principal product line, supposedly enables Macintosh and UNIX platforms to run substantially all MicroSoft Windows ("Windows") and MS-DOS ("DOS") applications by emulating the underlying hardware.  Insignia began shipping SoftWindows 2.0, the latest version of its principal product line, for Apple's Power Macintosh in August 1995 and for UNIX in October 1995.           (c)  According to Insignia, although MicroSoft's Windows had emerged as the leading computer operating system, Macintosh and UNIX platforms continued to succeed in various markets, such as desktop publishing and engineering applications, and many computer  users working in a Macintosh or UNIX environment chose to use some of the thousands of applications available for the Windows operating system, some of which did not have Macintosh or UNIX versions available.  Also, according to Insignia, incompatibility among various platforms often makes it difficult for users to run their applications of choice, creates workflow inefficiencies among users and complicates the roles of corporate MIS managers responsible for integrating and supporting organizations' computing resources across multiple platforms.  Insignia claimed to solve these incompatibility problems by providing cross-platform compatibility software with high levels of performance.      22.  (a)  Defendant Robert P. Lee ("Lee") is President, Chief Executive Officer and Chairman of the Board of Directors of Insignia.  Because of defendant Lee's position, he knew or COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                        - 9 -
recklessly disregarded the adverse non-public information about Insignia's business, finances, products, markets and present and future business prospects via access to internal corporate documents (including the Company's operating plans, budgets and forecasts and reports of actual operations compared thereto), conversations and connections with other corporate officers and employees, attendance at management and Board of Directors' meetings and committees thereof and via reports and other information provided to him in connection therewith.  Lee signed Insignia's l0-K for the fiscal year ended December 31, 1995.           (b)  Defendant Roger D. Friedberger ("Friedberger") was, until March 1996, the Chief Financial Officer and Senior Vice President-Finance and Operations of Insignia and Secretary of Insignia.  Because of defendant Friedberger's position, he knew or recklessly disregarded the adverse non-public information about Insignia's business, finances, products, markets and present and future business prospects via access to internal corporate documents (including the Company's operating plans, budgets and forecasts and reports of actual operations compared thereto), conversations and connections with other corporate officers and employees, attendance at management and Board of Directors' meetings and committees thereof and via reports and other information provided to him in connection therewith.  Friedberger signed Insignia's 10-K for the fiscal year ended December 31, 1995.           (c)  Defendant Richard M. Noling ("Noling") replaced Friedberger as Senior Vice President and Chief Financial Officer in March 1996.  Noling also was appointed head of the accounting, finance, MIS, legal, human resources, facilities and manufacturing COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 10 -
departments.  Because of defendant Noling's position, he knew or recklessly disregarded the adverse non-public information about Insignia's business, finances, products, markets and present and future business prospects via access to internal corporate documents (including the Company's operating plans, budgets and forecasts and reports of actual operations compared thereto), conversations and connections with other corporate officers and employees, attendance at management and Board of Directors' meetings and committees thereof and via reports and other information provided to him in connection therewith.  Noling signed Insignia's l0-Qs for the quarters ended March 31, 1996, June 30, 1996 and September 30, 1996.  Noling is a recidivist stock manipulator and violator of the securities laws.  Immediately before joining Insignia, as Chief Financial Officer of Gupta Corporation, he had participated in a scheme to defraud the investors of Gupta by engaging in a multitude of improper revenue recognition practices, thereby artificially inflating the stock price of that company.  The Gupta securities litigation, In re Gupta Corporation Sec. Litig., Master File No. 94-1517-FMS(EAI) (N.D. Cal.), in which Noling was a named defendant, settled in 1996, after Noling had joined Insignia, for $14.75 million. Insignia's shareholder were never informed of these facts.           (d)  Defendant Paul R. Griffiths ("Griffiths") is a director of Insignia.  Because of defendant Griffiths' position with Insignia, he knew or recklessly disregarded the adverse non- public information about Insignia's business, finances, products, markets and present and future business prospects via access to internal corporate documents (including the Company's operating  COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 11 -
plans, budgets and forecasts and reports of actual operations compared thereto), conversations and connections with other corporate officers and employees, attendance at management and Board of Directors' meetings and committees thereof and via reports and other information provided to him in connection therewith. Griffiths is a member of the Board of Directors of RIT Capital Partners plc ("RITCP"), a principal shareholder in Insignia.  RITCP with Griffiths sold 753,484 shares in the offering for $12 per ADS or $9 million.  Griffiths signed Insignia's 10-K for the fiscal year ended December 31, 1995.           (e)  Defendant John R. Johnston ("Johnston") is a director of Insignia.  Because of defendant Johnston's position with Insignia, he knew or recklessly disregarded the adverse non- public information about Insignia's business, finances, products, markets and present and future business prospects via access to internal corporate documents (including the Company's operating plans, budgets and forecasts and reports of actual operations compared thereto), conversations and connections with other corporate officers and employees, attendance at management and Board of Directors' meetings and committees thereof and via reports and other information provided to him in connection therewith.  A venture capital firm headed by Johnston sold 144,525 shares in the offering for $12 per ADS or $1.7 million.  Johnston signed Insignia's 10-K for the fiscal year ended December 31, 1995.           (f)  Defendant Nicholas A. Samuel ("Samuel") is a director of Insignia.  Because of defendant Samuel's position with Insignia, he knew or recklessly disregarded the adverse non-public information about Insignia's business, finances, products, markets COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 12 -
and present and future business prospects via access to internal corporate documents (including the Company's operating plans, budgets and forecasts and reports of actual operations compared thereto), conversations and connections with other corporate officers and employees, attendance at management and Board of Directors' meetings and committees thereof and via reports and other information provided to him in connection therewith.  A venture capital firm headed by Samuel sold 67,994 shares in the offering for $12 per ADS or $815,928.  Samuel signed Insignia's 10- X for the fiscal year ended December 31, 1995.           (g)  Defendant David L. Gibbs ("Gibbs") was Insignia's Vice President of North American Macintosh Product Sales.  In early 1996, Gibbs was promoted to Vice President Channel Sales.  Because of defendant Gibbs' position with the Company, he knew or recklessly disregarded the adverse non-public information about Insignia's business, finances, products, markets and present and future business prospects via access to internal corporate documents (including the Company's operating plans, budgets and forecasts and reports of actual operations compared thereto), conversations and connections with other corporate officers and employees, attendance at management meetings and via reports and other information provided to him in connection therewith.           (h)  The defendants identified in ¶22(a)-(g) are referred to herein as the Individual Defendants.  Each of the Individual Defendants, other than Noling and Gibbs, participated in the preparation of and/or signed the November 14, 1995 Registration Statement pursuant to which the Insignia ADSs were sold to the public and which contained the false and misleading statements COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 13 -
listed in ¶¶30-35.  Each of the Individual Defendants participated in the continuing scheme throughout the Class Period to issue false projections and false financial statements and drafting and/or reviewing the Company's press releases and public filings and by concealing the truth about Insignia's true prospects and its improper accounting practices.                      MOTIVE AND OPPORTUNITY      23.  Each Individual Defendant had the opportunity to commit and participate in the fraud described herein.  The Individual Defendants were officers and/or directors of Insignia and they controlled its press releases, corporate reports, SEC filings, preparation of its financial statements and its communications with analysts.  Thus, they controlled the public dissemination of, and could and did falsify, the information about Insignia's business and products that reached the public and impacted the price of its shares.      24.  Each of the Individual Defendants also had the motive to commit and participate in the fraud described herein.  Defendants wanted to and did cover up the problems with and deterioration in Insignia's business to make it appear that Insignia's business was succeeding and would achieve the earnings per share they had forecasted during the Class Period, so that its share price would trade at artificially inflated levels, high enough so that insiders could sell off significant amounts of their Insignia shares.      25.  Defendants, other than defendants Noling and Gibbs, were motivated to take Insignia public so that they could recover a portion of their investment in Insignia, escalate the book value of the shares they retained and create a market in which to sell their COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 14 -
shares.  Those defendants were aware by at least mid-1995 that they were in a difficult and threatened position.  They were "locked in" to Insignia, then a private corporation, without any way to realize on their investment because there was no trading market in which to sell their shares.  They knew also that Insignia's growth prospects were severely diminished, especially due to the introduction of Windows 95 and the growing popularity of the Windows 95 operating system which, in essence, made Insignia a "dead end" company, limited to selling software products to the shrinking Apple/ Macintosh and UNIX markets.      26.  To make the Offering a success, it was necessary to make it look as though Insignia would continue to grow and be profitable and that Insignia had new and successful products and would achieve strong revenue and profit growth, even though it was selling only to the Apple/Macintosh and UNIX markets.  Consequently, defendants were motivated to take and, in fact, took the opportunity presented by virtue of the power of their positions with the Company to arrange for the dissemination of false statements and false financial statements, portraying the Company as successful and growing in revenues and profits.  The trend in Insignia's reported revenues is shown by the following graph: COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 15 -
                     Insignia Solutions plc                        Quarterly Revenues
Insignia Chart 3

     27.  Aware that Insignia's business prospects actually were

declining by late 1995, defendants took full advantage of the third

quarter "growth."  Insignia embarked on the Offering, portraying

the Company as being in a "growth" mode even though it had no need

to raise capital for any business reason, such as expansion or new

product development.  The true purpose of the Offering was to raise

tens of millions of dollars from the investing public to benefit

Insignia's controlling shareholders and also enable them to dump

their Insignia ADSs.

     28.  In the Offering, several defendants took that opportunity

to sell significant amounts of their ADS holdings.  Griffiths sold

over 750,000 shares for over $9 million in proceeds.  Johnston sold

nearly 150,000 shares for $1.7 million in proceeds.  Samuel sold

nearly 70,000 shares for proceeds of over $815,000.


COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 16 -



     29.  After Insignia disclosed that its fourth quarter 1995 results would not meet the expectations defendants had fostered (but that revenues would decline) and after the price of Insignia's ADSs collapsed in response to the disclosure, defendants were motivated to avoid the complete collapse of Insignia's ADSs. Accordingly, defendants knowingly misrepresented Insignia's true deteriorating conditions and rendered false forecasts to the investing public.  At the same time, Insignia recognized revenue derived from transactions with customers who were granted secret discount and liberal return privileges for which the Company deliberately failed to reserve.  As a result, defendants issued false financial statements for the first three fiscal quarters of 1996 by overstating the revenue that could properly be recognized while, at the same time, the defendants issued forecasts that depended upon their improper "channel-stuffing" practices.           DEFENDANTS' FALSE AND MISLEADING STATEMENTS      30.  In the few weeks prior to the Offering, the underwriters and Insignia's top executives, including defendant Lee, conducted Roadshow meetings and individual investor presentations in several U.S. cities, including San Francisco, Boston and New York.  At the Roadshow meetings, very favorable information about Insignia was distributed, with the purpose and effect of overcoming and neutralizing the "risks" supposedly disclosed in the Prospectus and thereby further stimulating demand for Insignia ADSs to be sold in the Offering.  During the Roadshow meetings, the participants told potential investors:           (a)  That Insignia successfully operated in a niche market which provided it tremendous opportunities for growth in COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 17 -
selling cross-platform software to users of the Apple/Macintosh and UNIX computer operating systems, which growth would be achieved notwithstanding MicroSoft's 1995 successful introduction of the Windows 95 operating system and MicroSoft's growing dominance of computer operating systems;           (b)  That Insignia's SoftWindows 2.O for the Apple/ Macintosh introduced in August 1995 had been a tremendous success with strong distributor acceptance and retail sell-through;           (c)  That while Insignia's third quarter 1995 results reflected revenues from initial "channel-fill" of SoftWindows 2.0 for Apple/Macintosh, the amounts of this product shipped were normal and customary for new product introduction and Insignia had not engaged in "channel stuffing" to inflate its revenues for the third quarter;           (d)  That Insignia's SoftWindows 2.0 UNIX had been successfully introduced in October 1995 and had received an enthusiastic response from customers;           (e)  That Insignia's strong third quarter 1995 results indicated a trend of revenue growth which would continue in the fourth quarter of 1995, resulting in fourth quarter 1995 revenues of approximately $18 million, yielding fourth quarter 1995 earnings per share of $0.17-$O.18; and           (f)  That Insignia forecasted strong revenue and profit growth throughout 1996, with revenues of approximately $80-$82 million and earnings per share of $0.81-$O.82.      31.  The information disseminated during the Roadshow meetings was part of the total mix of information affecting Insignia's ADS COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 18 -
Offering on November 14, 1995 and the price of its ADSs on November 14, 1995, when they started trading.      32.  Insignia's November 14, 1995 Prospectus reported its third quarter revenues and earnings per share had increased very substantially and thus reinforced the impression that Insignia's revenues and profitability were growing.  The Prospectus stated:           The Company's total revenues have grown every year      since inception, except in 1993 when the market and the      Company's products were in transition from DOS to      Windows.  Also in 1993, the market was in transition to      RISC-based platforms sufficiently powerful to support the      Company's Windows products.  The Company's revenue growth      has resulted from the increasing number of platforms      available to run the Company's products, the improving      performance of the underlying hardware and the additional       functionality offered in new versions of the Company's      products. The Prospectus also showed that Insignia's revenues and earnings per share had jumped substantially in the third quarter of 1995, indicating that Insignia's revenue growth had resumed after three flat quarters:                                QUARTER ENDED  ========================================================================== |              3/31     6/30     9/30    12/31     3/23     6/30     9/30  | |              1994     1994     1994     1994     1995     1995     1995  | |--------------------------------------------------------------------------| | Revenues:                                                                | |  License                                                                 | |   revenue   $6,411   $7,866   $9,305  $12,211  $11,096  $10,834  $15,308 | |  Service                                                                 | |   revenue   $  715   $  905  $   922  $ 1,026  $ 1,347  $ 1,509  $ 1,000 | |--------------------------------------------------------------------------| | Total                                                                    | | Revenue     $7,126   $8,771  $10,227  $13,237  $12,443  $12,343  $16,308 | |--------------------------------------------------------------------------| | Net         $  490   $1,069   $1,271   $1,925   $1,484   $1,161   $1,982 | | Income                                                                   | |--------------------------------------------------------------------------| | Net         $ 0.04   $ 0.09   $ 0.11   $ 0.17   $ 0.13   $ 0.10   $ 0.17 | | income                                                                   | | per share                                                                |  ==========================================================================      33.  The large increase in Insignia's revenues during the third quarter, based on the introduction of SoftWindows 2.0 for the Apple/Macintosh market combined with defendants' representations COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 19 -
made in connection with the Offering, made it appear that Insignia's fourth quarter results would also show a large increase due to the introduction in October 1995 of SoftWindows 2.0 for UNIX.  The Prospectus reaffirmed this impression by stating:      Generally, sales volumes of new products increase in the      first few months following introduction of a new product      due to the purchase of upgrades by existing users and the      purchase of initial inventory by distribution channels. Moreover, Insignia represented during the Roadshow that sales of its UNIX-related products were normally higher in its fourth quarter, reinforcing this message in the Prospectus, which stated:      Although historically the Company's business has not been      subject to seasonal variations, the Company's sales of      products for UNIX workstations have been higher in the      fourth quarter as a result of customer purchase cycles      related to expiration of budgetary authorizations. These statements, indicating that sales of Insignia's SoftWindows 2.0 UNIX product would be strong in Insignia's fourth quarter of 1995, were extremely important to investors.  Insignia's investors knew that Insignia had clearer foresight into future sales of UNIX- related products as compared to Apple/Macintosh-related product sales because a majority of the Company's direct sales were for UNIX products, whereas Apple/Macintosh product sales were fulfilled through the distributor/retail sales channel.      34.  With respect to the sales and marketing of Insignia's products, the Prospectus stated:      Sales and Marketing           Insignia has built a complementary multiple channel      distribution system. . . .  Insignia's multiple channels      in the United States include OEM bundling arrangements,      distributors, retailers, direct sales and telesales.                               *  *  * COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 20 -
     Distributor and Retail Sales           Insignia has established a worldwide two-tier      distribution channel.  Its distributor relationships      include Ingram Micro and Merisel in North America,       Hewlett-Packard Germany in Europe and Mitsubishi in      Japan. . . .           . . . Currently, substantially all of the Company's      sales through the distributor channel are Macintosh       products. . . .  [A] portion of the Company's net      revenues in the third quarter of 1995 comprised initial      stocking orders of SoftWindows 2.0 for Power Macintosh.                               *  *  *      Direct Sales           The Company employs a sales force that sells      directly to organizations.  The Company's complementary      sales channel model integrates direct sales through OEMs      and distributors. . . . Currently, a majority of the      Company's total revenues from direct sales are UNIX       products. The Registration Statement and Prospectus warned of no significant risks concerning Insignia's sales and marketing organization, when defendants knew that Insignia's direct sales force was ineffective and ill-trained and was having serious problems in selling the new SoftWindows 2.0 UNIX product and could not sell Insignia's SoftWindows 2.0 Apple/Macintosh product effectively either.      35.  The Registration Statement and Prospectus were drafted so that they contained certain generic warnings of possible risks which concealed the fact that Insignia's business was already encountering the negative factors the Prospectus warned were only possible or contingent, including:      Potential Fluctuations In Operating Results                               *  *  *      Due to all of the foregoing factors, it is possible that      in some future quarters the Company's operating results      will be below the expectations of stock market analysts      and investors. COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 21 -
     Dependence upon UNIX Workstation Manufacturers and       Continued Demand for UNIX Platforms      . . . The Company's future success will depend on market      acceptance of SoftWindows 2.0 for UNIX, which the Company      began shipping in October 1995.                               *  *  *           The future success of the Company depends in part      upon the demand for the Company's products among users of       UNIX workstations . . . . Any decline in sales of UNIX      workstations would decrease the demand for the Company's      UNIX products and have a material adverse effect on the      Company's business, financial condition and results of       operations. By the time the Prospectus was disseminated to investors and the Registration Statement became effective, defendants already knew that Insignia's SoftWindows 2.0 UNIX product was meeting with poor success which would hurt Insignia's results in the short term.      36.  On December 11-12, 1995, almost immediately after the expiration of the SEC-mandated quiet period, analysts working for the underwriters circulated what are known in the underwriting community as "booster shots" (i.e., "shots" designed to "boost" the price of a stock) containing identical fourth quarter and full year 1995 revenue projections of $18 million and $59 million, respectively, and fourth quarter 1995 earnings per share of $0.17, on behalf of the defendants.  Defendants supplied these forecasts to analysts, knowing they were false, in order to maintain and further inflate the price at which Insignia's shares were then trading.      37.  On December 11, 1995, based on information supplied by Insignia executives, including defendant Lee,  Andrew Brousseau of Cowen & Co. ("Cowen") forecast earnings per share of $0.17 for the fourth quarter of 1995, year-end revenues of $59 million and COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 22 -
earnings per share of $0.59 for 1995 and 1996 earnings per share of $0.81 on revenues of $80 million; John F. Powers of Robertson Stephens & Co. forecast 1995 fourth quarter earnings per share of $0.17 and 1995 year-end revenues of $59.1 million and 1996 earnings per share, of $0.82 on revenues of $80 million.  On December 12, 1995, based on information supplied by Insignia's executives, including defendant Lee, Michael P. Wallace of UBS Securities forecast earnings per share of $0.17 for the fourth quarter of 1995, 1995 year-end revenues of $59 million and 1996 earnings per share of $0.82 on revenues of $81 million.      38.  Defendants' forecasts had the desired effect, pushing the Company's stock to a high of $22 per share on December 4, 1995. However, defendants knew that sales of its SoftWindows 2.0 product would likely not meet their forecasts for the fourth quarter of 1995 and beyond.  SoftWindows 2.0 UNIX sales were primarily direct sales as opposed to sales through distributors.  Insignia had begun shipping its new SoftWindows 2.0 UNIX in October 1995 and knew by mid-November 1995 that sales of this product were underperforming the defendants' projections.  Thus, Insignia did not have to estimate the "sell-through" and Insignia knew how unsuccessful the introduction of SoftWindows 2.0 UNIX actually was at the time of the Offering and on December 11, 1995, when analysts employed by the underwriters reiterated the glowing representations made by defendants Lee and Friedberger.  As for shipments of SoftWindows 2.0 Apple/Macintosh, Insignia had shipped product into the distribution channel in amounts so well above that normally shipped to "fill" the channel with inventory of a new product that COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 23 -
defendants knew it would start seeing returns of such product and sharply reduced sales.      39.  Initially, defendants' scheme was entirely successful. While the Offering price of Insignia ADSs was $12 per share, Insignia's ADS price advanced sharply, jumping to $14-3/4 per ADS on the day of the offering, $20-1/2 per ADS by November 30, 1995 (a 71%-increase in just 12 trading days) and later climbing to its Class Period high of $22 per ADS in early December 1995.  In addition to the $20+ million pocketed by Insignia insiders, including the defendants, the infusion of $20+ million of new capital into Insignia benefitted its controlling shareholders, instantly increasing the book value of the Insignia shares they owned by over 100% to $2.67 per share -- a $7.5 million windfall for these controlling shareholders.      40.  After the close of the market on January 2, 1996 -- just 33 trading days after the Offering and without any prior warning or indication -- Insignia suddenly revealed that its fourth quarter 1995 revenues would decline from third quarter levels of $16.3 million "due primarily to lower North American sales of its SoftWindows for UNIX products and, to a lesser extent, lower North American retail sales of its SoftWindows for Power Macintosh products," and, as a result, instead of earnings per share of $0.17 for the fourth quarter, it would report "approximately break-even results" for the December quarter.  This incredible revelation -- contrary to everything that defendants had earlier represented to investors to pull off the $43 million offering on November 14, 1995 -- resulted in an instant collapse of Insignia ADSs -- tumbling to as low as $5-1/4 per ADS on January 3 & 4, 1996 on 5.6 million COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 24 -
shares volume, a 56% two-day collapse, and a 74% drop from Insignia's $22 per ADS high just 20 trading days earlier.      41.  From the beginning of the Class Period through January 2, 1996, defendants (other than Noling who had yet to join Insignia), knew or should have known a host of adverse facts about Insignia's business and prospects.  These facts were concealed by defendants and they contradicted the statements and forecasts that had been disseminated.  These known, concealed facts included:           (a)  That Insignia's new SoftWindows 2.0 product for the Apple/Macintosh operating system introduced in August 1995 was not selling well through Insignia's distribution channel and that sales of this product were at such low levels that Insignia's revenues would decline, rather than increase, in the fourth quarter of 1995;           (b)  That Insignia knew that its customers for its SoftWindows 2.0 UNIX product would not be purchasing that product in sufficient quantities during the fourth quarter of 1995 to meet its forecasts and projections and that, therefore, it was likely that there would be a decline in Insignia's revenues in the fourth quarter;           (c)  That Insignia's new SoftWindows 2.0 product for the UNIX operating system introduced in October 1995 was not selling well and that sales of this product were at such low levels that Insignia's revenues would decline, rather than increase, in the fourth quarter of 1995;           (d)  That the introduction of MicroSoft's Windows 95 in August 1995 had badly damaged Insignia's business because Windows 95 contained a number of new and improved features which provided functions which operators formerly needed the Apple/Macintosh or COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 25 -
UNIX systems to perform and which had created demand in the past for Insignia's software emulation program products and thus there was not any reasonable basis for defendants' forecasts of strong growth for Insignia;           (e)  That Insignia had not created a complementary sales and marketing product distribution system as it had represented and, in fact, Insignia's direct sales marketing force was suffering from significant training deficiencies which interfered with their ability to sell Insignia's products, especially those designed for the Apple/Macintosh operating system;           (f)  That Insignia's direct sales force was disorganized and ineffective, suffering from inadequate training, such that Insignia was having difficulty selling its SoftWindows 2.0 products, and which would prevent Insignia from achieving the revenues and earnings per share forecast by and for it for the fourth quarter of 1995, as well as throughout 1996;           (g)  That Insignia was having difficulty selling its products for the UNIX operating system and was encountering difficulty in closing several large OEM deals for this product (including a large transaction with Silicon Graphics, Inc.) which made it virtually certain that Insignia's revenues and earnings per share would decline sharply in the fourth quarter of 1995 and be well below the level forecast by and for Insignia during 1996;           (h)  That Insignia's new SoftWindows 2.0 product for the UNIX market was not being well received by customers and, as a result, sales of that product would be much lower than internally budgeted or forecasted by Insignia for the fourth quarter of 1995 and during 1996 as well; COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 26 -
          (i)  That Insignia's direct sales and marketing force was not adequately trained or informed as to how to sell Insignia's new SoftWindows 2.0 UNIX product or its SoftWindows 2.0 Apple/Macintosh product and, as a result, sales of those products were very slow which would result in Insignia not obtaining the levels of revenues and earnings per share forecast by and for it during the fourth quarter of 1995 and during 1996 as well;           (j)  That Insignia did not compete favorably with respect to the important competitive factors identified in the Prospectus;           (k)  That Insignia's public offering had been planned and undertaken to permit Insignia's venture capital investors to bail out of a poor and losing investment and not for any bona fide or legitimate business reasons;           (1)  That Insignia's Offering price did not fairly reflect the Company's growth rate, the business potential of the Company or its present state of development but, rather, was fixed at an arbitrary and unfairly high level to benefit Insignia and the selling shareholders;           (m)  That as a result of the foregoing, Insignia's forecasts of strong revenue growth were false, as such growth was impossible to achieve in light of these undisclosed problems;           (n)  That defendants had no basis for their positive forecasts and projections regarding Insignia's revenues or earnings growth during 1995 and 1996, which statements were, in fact, false as they were inconsistent with the above negative factors;           (o)  That the forecasts of increased earnings per share for Insignia in its fourth quarter of 1995 to $0.17-$O.18 were COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 27 -
false, as they were contradicted by the adverse facts as set forth above and were not genuinely believed by defendants; and           (p)  That defendants did not genuinely believe their forecasts of $0.17-$O.18 earnings per share for the fourth quarter of 1995 or $0.81-$O.82 earnings per share for 1996, as they were aware of adverse information which contradicted these forecasts.      42.  In connection with their January 2, 1996 disclosures, and a to conceal the full impact of their fraudulent scheme, defendants again utilized securities analysts to disseminate false and misleading information about Insignia's condition and prospects. Based on information supplied by Insignia's executives, including defendant Lee, on January 3, 1996 Andrew Brousseau of Cowen reported the shocking news released the previous day by the Company, but stated:      Management remains comfortable with existing Street       estimates for 1996, but we are cutting our estimates      . . . by $9MM to $71MM (+27%) [and] . . . we are cutting       our EPS estimate by 26 to 55 (+38%). On January 29, 1996, based on information provided by Insignia's executives, including defendant Lee, Andrew Brousseau of Cowen forecast 1996 revenues of $65 million, with earnings per share for 1996 of $0.55 comprised of $0.06 for the first quarter, $0.12 for the second, $0.14 for the third and $0.23 for the fourth.      43.  However, defendants knew that even these revised forecasts could not be attained honestly and that to prevent an immediate and total collapse of Insignia's share price they would have to continue to "stuff the channel," issue false projections and disseminate false financial statements.  Therefore, continuing the practice that had begun at least by the time of the Offering, COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 28 -
through the fiscal third quarter of 1996, Insignia's North American Macintosh sales groups stuffed the Company's distribution channels with more product than could be absorbed by its customers by offering special incentives and secret, liberal rights of return. In a sweeping reorganization, Gibbs, Insignia's head of the Macintosh sales group who spearheaded the Company's channel- stuffing efforts, was elevated to the position of Vice President of Channel Sales for Macintosh and UNIX.  On January 22, 1996, it was reported via PR Newswire:           The company has integrated its former Macintosh(R)      and UNIX(R) sales groups into one sales organization,       jointly headed by David Gibbs, vice president of channel       sales and Bill McCarthy, vice president of corporate      sales.                               *  *  *           "Our newly-combined forces will allow us to make our      UNIX product line more accessible to the reseller and      distributor channels, and introduce our Macintosh product       line to previously untapped corporate opportunities.  The      combined sales organization is well situated to grow       business across the company's product lines by meeting      the company's objectives for 1996 and beyond."      44.  On March 21, 1996, after discussions with defendant Lee, Andrew Brousseau of Cowen reported:      Q1 Still Tight -- Discussions with management suggest       that the March quarter is on track but still tight.  The      Macintosh business is progressing on target and the UNIX       business is recovering somewhat from the Q4 shortfall,      but the, new NTrigue product is ramping up more slowly       than expected.  The company claims that NTrigue interest      and site growth is strong, but that user deployment is       lower than anticipated.  We estimate total revenues of      $14.7MM on $9.9MM in SoftWindows for Macintosh, $2.0MM in      SoftWindows UNIX and $1.5MM in NTrigue and EPS of 6*.      Although still hoping to meet expectations, management       claims that any shortfall against these estimates would      be small.      45.  Also on March 21, 1996, Insignia announced the appointment of defendant Noling as Senior vice President of Finance COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 29 -
and Operations and Chief Financial Officer.  Noling was also given responsibility for the Company's accounting, finance, MIS, legal, human resources, facilities and manufacturing departments.      46.  On April 23, 1996, Insignia announced its first quarter 1996 financial results:                                    Quarter Ended March 31,                                      1996           1995 Total Revenues                     $14,724        $12,443 Net income per share               $  0.06        $  0.13      47.  Following discussions with the Company on April 24, 1996, Michael P. Wallace of UBS Securities reported:      *    Insignia Solutions reported Q1 (March) EPS of $0.06           (versus $0.13), in line with our expectations.             Revenues were $14.7 million, up 5% sequentially and           up 18% year-to-year.      *    Growth in the UNIX channel returned to historical            levels, with UNIX sales reaching 31% of revenues           versus only 22% in the December quarter.  Concerns            about softness in the U.S. UNIX market have           dissipated somewhat.      *    The company continued to see good acceptance of its            new products SoftWindows 3.0, SoftWindows 95, and           NTrigue for WinFrame throughout the quarter, with            NTrigue products accounting for 7% of total sales           in their first revenue quarter.                               *  *  *      Q1 EPS in line.  Insignia reported first quarter EPS of       $0.06 (versus $0.13), in line with our estimate.      Revenues were also in line, coming in at $14.7 million       (versus $12.4 million).  International revenues accounted      for 27% of revenues, compared to 19% in 1Q95.  Revenue       growth was boosted mainly by good market acceptance of      new product releases, SoftWindows 3.0, SoftWindows 95,       and NTrigue for WinFrame.      48.  On or around May 15,1996, Insignia filed its Form 10-Q with the SEC for the quarter ended March 31, 1996.  In the 10-Q, which is signed by defendant Noling, defendants reported that COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 30 -
Insignia's first quarter revenues were $14.7 million, that net income was $749,000 and that earnings per share were $0.06. The 10-Q, further reported that "in the opinion of management, all adjustments . . . which are necessary for a fair presentation of the financial position had results for the interim period have been included."      49.  However, as defendants knew would be the case when they issued their misleading forecast for the first quarter of 1996, and when they filed Insignia's Form 10-Q for that quarter, Insignia's reported revenues and earnings for the first quarter were materially artificially inflated as a result of Insignia's improper recognition of revenue on contingent sales as described in ¶¶70-80.      50.  On July 23, 1996, the Company issued a press release which reported revenues of $15.7 million for the second quarter ended June 30, 1996, an increase of 27% compared to $12.3 million in the June 1995 quarter.  According to the press release, earnings per share for the June 1996 quarter were $0.11 on 13.0 million shares, compared to $0.10 on 11.4 million shares in the June 1995 quarter.  The Company reported revenues of $30.4 million for the six months ended June 30, 1996, an increase of 23% compared to $24.8 million in the prior year.  Earnings per share for the six- month period were $0.17 on 12.9 million shares, compared to $0.23 on 11.4 million shares in the prior year.      51.  Based on information provided by and at the direction of defendants, and by Lee and Noling in particular, on July 24, 1996, John F. Powers of Robertson Stephens reported that revenue from sales related to Apple/Macintosh were down only 16% from the prior quarter. COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 31 -
                           Revenue Mix                             % of rev.                           Q1        Q2      Apple related        57        41      Unix related         31        31      NTrigue               7        12      NT                    5        15      Other                 1         1 However, Insignia was stuffing the channel with Apple/Macintosh and UNIX SoftWindows products and recognizing as revenue sales which were contingent in violation of GAAP.  Thus, defendants knew that the actual percentage of revenue derived from Apple/Macintosh and UNIX emulation products was much lower than publicly reported.      52.  Based on information provided by and at the direction of the Company, and by Lee and Noling in particular, on July 24, 1996, Michael P. Wallace of UBS Securities reported:           Offsetting this revenue growth were higher than      expected above- and below-the-line expenses.  Gross       margins of 70% were nearly 2% below our expectations.      This was mostly due to higher royalty payments associated       with the company's NTrigue products, which grew faster      than we anticipated.  S&M expenses came in at 37.4% of       revenues; we were looking for 33%.  Finally, G&A outpaced      our expectations, coming in at 9.7%; we were looking for       8.5%.  Most of this increase was due to a $250,000 charge      taken against the uninsured portion of shareholder       litigation costs related to the class action law suit      filed against the company last Spring. . . .      2H96 Outlook           Looking ahead to the second half of the year, we      expect to see good revenue growth, especially as NT      becomes more widely accepted in the corporate       environment.  Mac-related sales should be flat      sequentially, and NTrigue should continue to grow as a       percent of revenues.  While this helps revenue growth, it      puts pressure on margins because of the higher royalty       payments associated with the product.  As a result, we      are lowering our 1996 EPS estimate to $0.45 from $0.60       and our 1997 EPS to $0.75 from $0.80. We retain our Hold      in INSGY. COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 32 -
     53.  Based on information provided by and at the direction of defendants, and by Lee and Noling in particular, on July 26, 1996, Andrew Brosseau of Cowen reported:           Annual EPS                   Quarterly EPS FY                              Q1       Q2     Q3     Q4 (Dec) 1995      $0.42     $0.37      $0.13    $0.10  $0.18  $0.05 1996E      0.45      0.45       0.06A    0.11A  0.12   0.18 1996E      0.60      0.60       0.10     0.13   0.15   0.22      Q2 revenues of $15.7MM (+27%) finished just above our      estimate, but EPS of 11c needed a good boost from taxes       to finish in the midrange of Street expectations. . . .      Revenues were mixed.  On the one hand, SoftWindows for       Unix (+42%) is recovering from the Q4:95 shortfall and      NTrigue is finally beginning to gain momentum, with sales       jumping sharply from last quarter to 11% of revenues-in      Q2.  This, along with healthy growth in Windows NT       royalties were key to revenues.  On the other hand,      SoftWindows for Macintosh (-5% and 38% of total) is doing       poorly, with sales slowing sharply following the new      product sell-in in Q1.  Gross margins of 70% were in       line, but operating expenses (+37%) were somewhat higher      than expected, due partly to one-time legal fees stemming       from the shareholder lawsuit.                               *  *  *      We are maintaining our 1996-97 EPS estimates on finetuned      revenue and expense assumptions.  For 1996, we look for       revenues to reach $65MM (+18%) on license sales of $60MM      (+19%) and services fees of $5MM (+13%).  Among the major       product lines, we expect SoftWindows for Mac revenues      $26MM (-19%), SoftWindows for Unix of $20MM (+52%),       NTrigue sales of $9MM, and NT royalties of $5MM.  Gross      margins should stay around 70% and operating expenses       should flatten over coming quarters, bringing operating      margins to 10% and EPS to 45c.  For 1997, we project       revenues of $77MM (+18%) and EPS of 60c (+33%) on 12.5%      operating margins.      54.  On or around August 14, 1996, Insignia filed its Form 10-Q with the SEC for the quarter ended June 30, 1996.  In the 10-Q, which is signed by defendant Noling, defendants represented that Insignia's second quarter revenues were $15.7 million, that net income was $1.45 million and that earnings per share were COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 33 -
$0.11. In the 10-Q, defendants also report that "in the opinion of management, all adjustments . . . which are necessary for a fair presentation of the financial position and results for the interim period have been included."      55.  However, as defendants knew would be the case when they issued their misleading forecast for the second quarter of 1996 and when they filed Insignia's Form 10-Q for that quarter, Insignia's reported revenues and earnings for the second quarter were materially artificially inflated as a result of Insignia's improper recognition of revenue on contingent sales as described in ¶¶70-80. Lee attributed Insignia's false financial results to the success of Insignia's products claiming:           "The revenues for the second quarter reflected a      healthy growth of our Windows(R) NT(R)-based NTRIGUE(TM)      product line." . . .  "In fact, NTRIGUE was awarded       Analyst's Choice in this week's issue of PC Week      (July 22, 1996), which summarized NTRIGUE 2.0 as 'an       excellent choice for companies that want to standardize      on Windows applications but still let networked users       work on the platform of their choice -- ranging from x86      PCs to Mac and UNIX workstations."'      56.  Based on information provided by and at the direction of defendants, and by Lee and Noling in particular, on September 11, 1996, Michael P. Wallace of UBS Securities reported:           We met with management yesterday and got a brief      update on the current quarter and business in      general. . . . The two key issues to focus on here are       the ramp-up of NTrigue, the company's most recent      product, and the effect of weak Macintosh sales on       Insignia's business.                               *  *  *           Q3 Outlook.  For the September quarter we are      looking for revenues of $16.8 million (vs. $15.7 last       quarter and $16.3 million a year ago) and EPS of $0.13      (vs. $0.11 last quarter and $0.17 last year).  There is       a chance that revenues come in light, given the big      question mark for Mac-related sales.  If revenues come in COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 34 -
     $1 million short, using the above scenario, EPS would       likely be around $0.11 or $0.12.  Cost cutting may      recover some of this, but the company is approaching the       limits of how much it can trim back operating expenses.      57.  Based on information provided by and at the direction of defendants, and by Lee and Noling in particular, on October 10, 1996, John F. Powers of Robertson Stephens issued a report which reiterated prior projected revenue and earnings estimates of $65.4 million for fiscal year 1996 with earnings per share of and $0.35, $16.8 million for the third quarter with earnings per share of $0.12.      58.  However, on October 15, 1996, the Company issued a press release announcing financial results for the third quarter ended September 30, 1996.  The Company reported revenues of $9.1 million, for a loss of $0.44 per share.  The Company reported revenues of $39.5 million for the nine months ended September 30, 1996, a decrease of 4% compared to $41 million in the prior year.  This represented a loss per share of $0.22 on 12.5 million shares for the nine-month period, compared to earnings of $0.41 on 11.4 million shares for the same period in the prior year.      59.  On October 17, 1996, based on information provided by Insignia's executives, including Lee and Noling, Andrew Brosseau of Cowen reported that Insignia's management blamed the "huge operating loss" on "poor reordering by the channel" and "[d]efferal of SoftWindows for Unix revenues from a multi-million [dollar] deal with SGI."      60.  On or around November 14, 1996, Insignia filed its Form 10-Q with the SEC for the period ended September 30, 1996.  In the 10-Q, which is signed by defendant Noling, defendants represent COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 35 -
that Insignia's third quarter revenues were $9.1 million, that the net loss for the quarter was $5 million  and that net losses per share were $0.44. In the 10-Q, defendants represent that "in the opinion of management, all adjustments which are necessary for a fair statement of the financial position and results for the interim period have been included."      61.  These third quarter financial results, disappointing as they were, still were materially inflated due to the channel stuffing and improper revenue-recognition practices described herein.  In reaction to the Company's abject failure to meet its forecasts, Insignia ADSs collapsed from $6 to $4 per share.      62.  After the third quarter results had been announced, defendants were aware that the truth about Insignia's condition and prospects would become more and more difficult to conceal.  In an effort to blame solely lower level employees and not the Board of Directors and senior executives, defendants fired Stuart McIntosh accusing him of improper channel-stuffing and other related improprieties.      63.  However, on February 3, 1997, McIntosh responded by filing a complaint in the Orange County Superior Court against Insignia, Gibbs and unnamed Does for breach of contract and tortious conduct in association with his dismissal.  McIntosh alleges, inter alia, that:      Defendants, and each of them, in discharging plaintiff       accused plaintiff of formulating a distribution process      known as "stuffing the channel" and the numerous business       ramifications involved in said distribution process.  At      the time of discharge, defendants, and each of them, knew       or should have known that the plaintiff was not      responsible for Insignia's distribution policies involved       in "stuffing the channel." COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 36 -
Complaint, McIntosh v. Insignia Solutions, Inc., et al., Case No. 774906 (Orange County Sup. Ct., filed Feb. 3, 1997).      64.  Finally, on February 27, 1997, while Price Waterhouse was performing its audit of Insignia's 1996 financial results, the Company admitted that its channel-stuffing practices had led to Insignia's improperly recognizing revenue in the first two quarters of 1996, necessitating the restatement of earnings and revenues for each period.  Thereafter, Insignia's share price collapsed to $2-1/2 per share.            MANAGEMENT'S RESPONSIBILITY FOR INTERNAL         ACCOUNTING CONTROL AND FOR FINANCIAL REPORTING      65.  Insignia had a responsibility to maintain sufficient accounting controls to accurately report its financial results.  It is well-settled that the representations made by a company in its financial statements and in other financial disclosures to the public are the representations of that company's management. Indeed, even, as in Insignia's case, when a company issues audited financial statements together with the report of that company's independent auditors, that report always expressly provides that "the financial statements are the responsibility of the company's management."      66.  To accomplish the objectives of accurately recording, processing, summarizing and reporting financial data, a company must establish an internal control structure.  In that structure, according to Appendix D to Statement on Auditing Standards No. 55, Consideration of the Internal Control Structure in a Financial  Statement Audit ("SAS 55"), management should consider, among other things, such objectives as (i) making certain that "[t]ransactions COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 37 -
are recorded as necessary . . . to permit preparation of financial statements in conformity with generally accepted accounting principles . . . and to maintain accountability for assets," and (ii) making certain that "[t]he recorded accountability for assets is compared with the existing assets at reasonable intervals and appropriate action is taken with respect to any differences."      67.  As described in SAS 55, the applicability and importance, of specific control environment factors, accounting system methods and records and control procedures that an entity should establish should be considered within the context of such criteria as an entity's size, its organization and ownership characteristics, the nature of its business, the diversity and complexity of its operations, the entity's method of processing data, and its applicable legal and regulatory requirements.  In short, the larger the entity, the more the nature of the entity's business is complex, diverse and sophisticated, and the public ownership of the entity customarily requires a sophisticated internal control structure to ensure that transactions are accurately recorded and that, prior to the public disclosure of any financial information, such transactions are compared to the existing assets (e.g., comparing inventory as recorded on a company's books to those amounts actually "on hand") to eliminate any discrepancies between the recorded and actual amounts.      68.  According to SAS 55:           Establishing and maintaining an internal control      structure is an important management responsibility.  To       provide reasonable assurance that an entity's objectives       will be achieved, the internal control structure should      be under ongoing supervision by management to determine       that it is operating as intended and that it is modified      as appropriate for changes in conditions. COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 38 -
     69.  When management permits a condition to exist in the company's internal control structure such that      the design or operation of one or more of the internal      control structure elements does not reduce to a      relatively low level the risk that errors or       irregularities in amounts that would be material in      relation to the financial statements . . . may occur and       not be detected within a timely period by employees in      the normal course of performing their assigned functions, that condition is defined by Statement on Auditing Standards No. 60, Communications of Internal Control Structure Related Matters  Noted in an Audit ("SAS 60"), as a "material weakness" in the company's internal control structure.                  FALSE FINANCIAL STATEMENTS      70.  GAAP are those principles recognized by the accounting profession as the conventions, rules and procedures necessary to define accepted accounting practice at a particular time. Regulation S-X (17 C.F.R. §210.4-01 (a) (1)) states that financial statements filed with the SEC which are not prepared in compliance with GAAP are presumed to be misleading and inaccurate.      71.  On or around March 26, 1996, Insignia represented in its Annual Report for the year ended December 31, 1995, the following with regard to its revenue recognition practices:      The Company recognizes revenue in accordance with the       American Institute of Certified Public Accountants'      Statement of Position 91-1 on Software Revenue Recogni-      tion.                               *  *  *           Product licensing fees are recognized upon shipment      if no significant vendor obligations remain and if       collection of the resulting receivable is deemed      probable.  The Company grants distributors and resellers       certain rights of return and price protection on unsold      merchandise held by those distributors and resellers.      Accordingly, reserves for estimated future returns, COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 39 -
     exchanges and credits for price protection are accrued      upon product shipment.      72.  In its interim reports for 1996, filed with the SEC on May 15, 1996, August 13, 1996, and November 14, 1996, respectively, Insignia represented the following with regard to the accompanying financial information:           The condensed consolidated financial statements are      unaudited.  However, in the opinion of management, all       adjustments (consisting only of normal recurring      adjustments) which are necessary for a fair presentation      of the financial position and results for the interim      period have been included.      73.  These representations with regard to Insignia's financial statements and revenue recognition practices were false and misleading due the Company's violation of GAAP, as set forth in Statement of Position ("SOP") 91-1 and other pronouncements.      74.  GAAP, as set forth in the FASB Statement of Concepts ("Concepts") No. 5, provides the basic requirements for the recognition of revenue.  Concepts No. 5, ¶83 requires that revenue be realizable (or collectible) prior to recognition and also that revenue be "earned," prior to recognition, meaning that an entity has "substantially accomplished what it must do to be entitled to the benefits represented by the revenues."      75.  SOP 91-1 requires that revenue not be recognized on software licenses unless: (a) delivery has occurred; (b) other remaining vendor obligations are no longer significant; and (c) collectibility is probable.  SOP 91-1.34. Revenue from cancelable licenses should not be recognized until cancellation privileges lapse.  SOP 91-1.53.  Transactions in which companies are granted the right to exchange software products for different software products or for similar software products with more than COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 40 -
minimal differences in price, functionality, or features are considered returns that should be accounted for in conformity with FASB Statement No. 48.1 SOP 91-1.54.      76.  During the Class Period, Insignia entered into agreements with certain of its distributors and resellers which granted those distributors and resellers the right to cancel certain software license agreements and the right to exchange software products for refunds or for different types of software.  In violation of GAAP, Insignia reported these transactions as revenue and failed to adequately reserve for estimated returns and/or cancellation.  The impact of these misstatements was to materially misstate the company's revenues, earnings and assets during the Class Period.      77.  As a result of the Company's improper revenue recognition, the Company materially inflated its earnings during the Class Period.  The Company's improper revenue recognition caused its collection of accounts receivable to decrease dramatically.  Whereas Insignia's average collection time as measured by days' sales outstanding ("dso," a calculation of the average time it takes Insignia to collect on its receivables based on current quarter sales) was only 28 days at September 30, 1995, by March 31, 1996 it had grown to 86 days, and by September 30, 1996 it had grown to 140 days.  Insignia's customers stopped paying _____________________ 1    FASB Statement No. 48 requires that where the right of return exists, certain conditions must all be met prior to revenue being recognized on those transactions.  The conditions include the following: (i) the obligation of the buyer to pay the seller is not contingent on resale of the product; (ii) the seller does not have significant obligations to bring about the resale of the product by the buyer; and (iii) the amount of future returns can be reasonably estimated.  SFAS No. 48, ¶6.  Where revenue is recognized because these conditions are met, any costs or losses that may be expected  in connection with any returns shall be accrued.  SFAS No. 48,¶7. COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 41 -
at the same rate they had in earlier periods due to the fact they did not believe they owed the money based on the agreements they had with Insignia that certain of the sales with these customers were contingent on acceptance or were subject to cancellation.      78.  Ultimately in the fourth quarter of 1996, when the Company was in the midst of its year-end audit, the improper revenue recognition was discovered by the Company's external auditors.  On February 27, 1997, Insignia for the first time revealed that its results were misstated.  Insignia reported that it would restate its results for the first and second quarters of 1996.      79.  In fact, the Company's restated amounts are dramatically different than those reported for the first two quarters of 1996:                     Insignia Solutions plc                 Reported and Restated Revenues
Insignia Chart 4

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 42 -



                    Insignia Solutions plc                       Earnings Per Share
Insignia Chart 5

     80.  In its financial statements for the nine months ended

September 30, 1996, Insignia reported revenues of $39.5 million and

net accounts receivable of $11.7 million.  When Insignia released

is its fourth quarter and year-end 1996 results, it reported net

accounts receivable of only $6..9 million and, from the amount of

revenue Insignia reported for the fourth quarter and year ended

December 31, 1996, it is now apparent that Insignia's revenues for

the nine months ended September 30, 1996 were actually only $37.1

million.  Whereas Insignia originally reported a net loss of $2.8

million for the nine months ended September 30, 1996, it is now

apparent Insignia incurred a loss of $4.6 million for the nine

months ended September 30, 1996.


COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 43 -



                  DEFENDANTS' INSIDER TRADING      81.  As part of defendants' scheme, Insignia's insiders sold $20+ million of Insignia ADSs in the Offering, to profit from the artificial inflation in Insignia's ADS price their fraud had created before the truth became known and Insignia's ADS price crashed.  Notwithstanding their access to material non-public information obtained in connection with the Offering and prior thereto, and as a result of their positions with the Company, Insignia's insiders sold the following amounts of Insignia ADSs, at artificially inflated prices while in possession of material non- public information:                              NUMBER OF SHARES     PRICE INSIDER                           OFFERED       PER SHARE      PROCEEDS -------                      ----------------   ---------      -------- Griffiths, Paul R.                753,484          $12       $9,041,808 Johnston, John R.                 144,525          $12       $1,734,300 Gilde Venture Fund B.V.           267,623          $12       $3,211,476 Samuel, Nicholas A.                67,994          $12         $815,928 Euroventures Benelux B.V.         175,416          $12       $2,104,992 Hancock International              79,476          $12         $953,712 Private Equity Partners L.P. Euroventures (UK) B.V.            101,313          $12       $1,215,756 Others                            158,586          $12       $1,903,032                                 ---------                   -----------            TOTAL:               1,748,417                   $20,981,004      82.  On May 13, 1996, after he had left the Company, but while he was aware of the continuing fraudulent scheme, defendant Friedberger sold 10,000 shares at $9 per share, realizing proceeds of $90,000.                      STATUTORY SAFE HARBOR      83.  The statutory safe harbor provided for forward-looking statements under certain circumstances does not apply to any of the allegedly false statements pleaded in this Complaint.  The safe COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 44 -
harbor has no application to conduct that predated its enactment, nor does it apply to statements associated with the offering.  None of the statements pleaded herein were sufficiently identified as "forward-looking statements" when made.  Nor were any of the statements accompanied by meaningful cautionary statements identifying important factors that could cause actual results to differ materially from the statements made.  Alternatively, to the extent that the statutory safe harbor does apply to any statements pleaded herein, because they are deemed to be "forward-looking," defendants are liable for those statements because at the time each of those statements was made, the speaker knew the statement was false and the statement was authorized and/or approved by an executive officer of Insignia who knew that the statement was false.                             COUNT I      For Violations of Section 10(b) Of The Exchange         Act And Rule 10b-5 Against All Defendants      84.  Plaintiffs incorporate by reference ¶¶1-83, above, as if set forth fully herein.      85.  The defendants knew, or were reckless in failing to know, of the material omissions from and misrepresentations contained in the statements as set forth above.  Each of the defendants: (a) knew or had access to the material adverse non-public information about Insignia's financial results and then existing business conditions, which was not disclosed; and (b) participated in drafting, reviewing and/or approving the misleading statements, releases, reports and other public representations including SEC filings of and about Insignia. COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 45 -
     86.  Throughout the Class Period, defendants, with knowledge of or reckless disregard for the truth, disseminated or approved releases, statements and reports, referred to above, which were misleading in that they contained misrepresentations and failed to disclose material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading.      87.  During the Class Period, defendants, individually and via a scheme, directly and indirectly, participated in a common course of business to conceal material adverse information regarding the financial performance of the Company and the then existing business conditions as specified herein.  Defendants employed devices, schemes and artifices to defraud and engaged in acts, practices and a course of business as herein alleged to commit a fraud on the integrity of the market for the Company's ADSs and to maintain artificially high market prices for the ADSs of Insignia.  This included the formulation, making of and/or participation in the making of untrue statements of material facts and the omission to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading, and engaging in the acts, practices and a course of business which operated as a fraud and deceit upon plaintiffs and the Class, all of the above in connection with the IPO of Insignia ADSs to plaintiffs and members of the Class.      88.  By reason of the conduct alleged herein, defendants knowingly or recklessly, directly or indirectly, have violated §10(b) of the Exchange Act and Rule 10b-5 promulgated thereunder in that they: (a) employed devices, schemes and artifices to defraud; COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 46 -
(b) made untrue statements of material facts or omitted to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; or (c) engaged in acts, practices and a course of business that operated as a fraud or deceit upon plaintiffs and others similarly situated in connection with their purchases of Insignia shares during the Class Period.      89.  Plaintiffs and the Class have suffered substantial damages in that, in reliance on the integrity of the market, they paid artificially inflated prices for Insignia shares as a result of defendants' violations of §10(b) of the Exchange Act and SEC Rule 10b-5.  Plaintiffs and the Class would not have purchased Insignia ADSs at the prices they paid, or at all, if they had been aware that the market prices had been artificially and falsely inflated-by defendants' misleading statements and concealment.  At the time of the purchases by plaintiffs and the Class of Insignia ADSs, the fair and true market value of said ADSs was substantially less than the prices paid by them.                            COUNT II                 For Violation Of Section 20(a)           Of The Exchange Act Against All Defendants      90.  Plaintiffs incorporate by reference ¶¶1-89, above, as if set forth fully herein.      91.  The Individual Defendants each acted as controlling persons of Insignia within the meaning of §20(a) of the Exchange Act.  By reason of their positions as officers and/or directors of Insignia and also because of their interest in Insignia ADSs, they had the power and authority to cause Insignia to engage in the COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 47 -
wrongful conduct complained of herein.  Insignia controlled each of the Individual Defendants and all of its employees.      92.  By reason of such wrongful conduct, the defendants named in this count are liable pursuant to §20(a) of the Exchange Act. As a direct and proximate result of these defendants' wrongful conduct, plaintiffs and the other members of the Class suffered damages in connection with their purchases of the Company's securities during the Class Period.                      BASIS OF ALLEGATIONS      93.  Plaintiffs have alleged the foregoing based upon the investigation of their counsel, which included a review of Insignia's SEC filings, securities analysts' reports and advisories about the Company, press releases issued by the Company, media reports about the Company and discussions with consultants, and believe that substantial evidentiary support will exist for the allegations set forth in ¶¶2-9, 24-44, 47, 49, 51-53, 55-57, 59 61- 62 and 04-83 after a reasonable opportunity for discovery.                        PRAYER FOR RELIEF      WHEREFORE, plaintiffs pray for judgment as follows:      1.   Declaring this action to be a proper class action pursuant to Rule 23 (a) and (b) (3) of the Federal Rules of Civil Procedure on behalf of the Class defined herein;      2.   Awarding plaintiffs and the members of the Class compensatory damages;      3.   Awarding plaintiffs and the members of the Class pre-judgment and post-judgment interest, as well as reasonable attorneys, fees, expert witness fees and other costs; COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS                       - 48 -
     4.   Awarding extraordinary, equitable and/or injunctive relief as permitted by law, equity and the federal statutory provisions sued hereunder, including the imposition of a construc- tive trust upon the proceeds of defendants' insider trading, pursuant to Rules 64, 65 and any appropriate state law remedies; and      5.   Awarding such other relief as this Court may deem just and proper.                           JURY DEMAND       Plaintiffs demand a trial by jury. DATED: March 21, 1997                                    MILBERG WEISS BERSHAD                                      HYNES & LERACH LLP                                     WILLIAM S. LERACH                                    ALAN SCHULMAN                                     MARK SOLOMON                                               /s/                                    __________________________                                         ALAN SCHULMAN                                    600 West Broadway, Suite 1800                                     San Diego, CA  92101                                     Telephone:  619/231-1058                                    MILBERG WEISS BERSHAD                                       HYNES & LERACH LLP                                    KIMBERLY C. EPSTEIN                                     222 Kearny Street, 10th Floor                                    San Francisco, CA  94108                                     Telephone:  415/288-4545                                    WEISS & YOURMAN                                    JOSEPH H. WEISS                                     JACK I. ZWICK                                    551 Fifth Avenue                                     Suite 1600                                    New York, NY  10176                                     Telephone:  212/682-3025 COMPLAINT FOR VIOLATION OF THE FEDERAL SECU