LIONEL Z. GLANCY #134180
TRACY L. THROWER #145782
MICHAEL GOLDBERG #188669
LAW OFFICES OF LIONEL Z. GLANCY
1801 Avenue of the Stars
Suite 308
Los Angeles, California  90067
(310) 201-9150

IRA M. PRESS
KIRBY McINERNEY & SQUIRE, LLP
830 Third Avenue
10th Floor
New York, New York  10022
(212) 317-2300

Attorneys for Plaintiff


                  UNITED STATES DISTRICT COURT

                 NORTHERN DISTRICT OF CALIFORNIA

___________________________________
ELLIS INVESTMENT CO., LTD.,        | Civil Action. No.
personally, and on behalf of all   | 99-CV-1102  BZED
others similarly situated,         | [filed Mar. 10, 1999]
                                   |
     Plaintiff,                    | Hon. Bernard Zimmerman
                                   |
     v.                            | CLASS ACTION COMPLAINT
                                   | FOR VIOLATION OF FEDERAL
ADVANCED MICRO DEVICES, INC. and   | SECURITIES LAWS
JERRY SANDERS,                     |
                                   | 
     Defendants.                   | JURY TRIAL DEMANDED
___________________________________|

          Plaintiff, through counsel, alleges as follows, based 

on information and belief, except those allegations which 

pertain to the named plaintiff, which are based on personal 

knowledge.   Plaintiff's information and belief is based, inter 

alia, on the investigation made by and through counsel, 

primarily from public filings, statements, and releases made by 

defendants.

                      OVERVIEW OF ACTION

          1.   This is a class action on behalf of all 

purchasers of securities issued by Advanced Micro Devices, Inc. 

("AMD" or the "Company") between November 12, 1998 and January 

13, 1999, inclusive (the "Class Period"), seeking remedies 

under the Securities Exchange Act of 1934 (the "Exchange Act").

          2.   In late October 1998, AMD cut prices on its 

personal computer-compatible microprocessors by nearly 30% in 

an effort to boost sales.  Thereafter, the Company boasted 

publicly of increased demand for its products, particularly its 

K6 processor.  In November 1998, Company management, including 

defendant Jerry Sanders, AMD's Chief Executive Officer, told 

securities analysts that the Company expected a significant 

increase in sales in the 1998 fourth quarter (then already well 

underway) as well as a significant increase in AMD's market 

share (relative to industry leader, Intel Corporation).  At the 

time of the conference call, and/or thereafter during the Class 

Period, defendants knew or in the absence of recklessness 

should have known that AMD's projected increase in demand and 

sales in the 4th quarter could not translate into an increase 

in revenues or earnings unless AMD could remedy design and 

production problems with its K-6 microprocessor.  Neither this 

fact, nor the existence of the design and production problems 

were disclosed to the investing public during the Class Period.  

Accordingly, the investment community believed that AMD's 

pricing strategy was a success, and AMD was poised for a 

successful fourth quarter.  Based on defendants' statements, 

securities analysts raised their estimates of AMD's 4th quarter 

earnings, and AMD's stock price rose quickly, from just $17 per 

share on October 22, 1998 to a Class Period high of $32 per 

share.

          3.   At the close of fourth quarter, analysts were 

still optimistic about the Company, as they had no reason to 

suspect that AMD had not been able to take advantage of the 

increased demand for its processors. 

          4.   Unbeknownst to the investing public, AMD's much-

ballyhooed road to success in the 1998 fourth quarter had hit a 

major pothole.  The demand for the K6  processor was there, but 

design and production flaws rendered the K6 unfit to meet that 

demand.  Because of these undisclosed problems, AMD was not 

able to sell many of its high-speed 400 MHz and 350 MHz K6 

chips, which are priced from $158 to $283.  Instead, most of 

AMD's sales were of the 300 MHz K6 chip, which sells for less 

than $80. 

          5.   Unsuspecting investors were stunned when on 

January 13, 1999 (more than two weeks after the fourth quarter 

ended), AMD disclosed to the marketplace that it had not been 

able to meet the increased demand for its products in the 

fourth quarter because design and production flaws sharply 

decreased the number of high powered microprocessors that the 

Company was able to sell in the quarter.  As a result, the 

Company announced quarterly earnings that were significantly 

below analysts' estimates.

          6.   The fallout from the January 13, 1999 

announcement was swift and devastating.  The Company's stock 

price dropped from $27 3/4 per share on January 13, 1999 to 

close at $22 1/2 per share the following day, a single day 

decline of nearly 20%. 

          7.   By the acts, transactions, and courses of 

conduct alleged herein, defendants, individually and acting 

with others in a common plan and scheme, deceived the plaintiff 

and the Plaintiff Class and deprived them unfairly of the full 

value of their investments in AMD in violation of the federal 

securities laws.

                    JURISDICTION AND VENUE

          8.   The jurisdiction of this Court is founded upon 

Section 27 of the Securities Exchange Act of 1934, 15 U.S.C. 

§78aa (the "1934 Act"), and 28 U.S.C. §1331.  The claims set 

forth herein arise under Sections 10(b) and 20(a) of the 1934 

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

rules promulgated thereunder (17 C.F.R. §240.10b-5).

          9.   Venue is proper in this District pursuant to §27 

of the Exchange Act, and 28 U.S.C. §1391.  A substantial part 

of the acts and events giving rise to the violations complained 

of, including the dissemination of reports, updates and other 

false and misleading information, occurred in this District.  

In addition, defendant AMD maintains its principal offices in 

this District.

          10.  In connection with the acts, conduct, and other 

wrongs complained of herein, the defendants, directly and 

indirectly, used the means and instrumentalities of interstate 

commerce, including the mails, interstate telephone 

communications, and the facilities of a national securities 

exchange.

                           PARTIES

          11.  Plaintiff Ellis Investment Co., Ltd. purchased 

shares of AMD common stock during the Class Period, as set 

forth in the accompanying certification, and has been damaged 

thereby.  Plaintiff and the putative class are herein referred 

to as "Plaintiff Class." 

          12.  Defendant AMD is a California-based producer of 

computer microprocessors, located at One AMD Place, Sunnyvale, 

California, which operates facilities in the U.S. and Asia, and 

maintains sales offices worldwide.  As of October 1998, the 

Company had nearly 145 million shares of common stock 

outstanding, and its shares traded on the New York Stock 

Exchange under ticker symbol AMD.

          13.  Defendant Sanders is AMD's Chief Executive 

Officer.  As such, defendant Sanders had a duty to disseminate 

complete, accurate and truthful information regarding AMD's 

business operations.  Defendant Sanders had a duty to correct 

promptly any public statements issued by the Company which had 

become false and misleading.   Defendant Sanders, as Chief 

Executive Officer of the Company, actively participated in the 

issuance of the false financial information complained of 

herein.  Because of his position, his ability to exercise power 

and influence with respect to AMD's course of conduct and his 

access to material inside information about the Company, 

Defendant Sanders was, at the time of the wrongs alleged 

herein, a controlling person of AMD within the meaning of 

§20(a) of the 1934 Act.

                PLAINTIFF'S CLASS ALLEGATIONS

          14.  Plaintiff brings this action as a class action 

pursuant to Federal Rules of Civil Procedure 23(a) and (b)(3) 

on behalf of a class (the "Class") consisting of all persons 

and entities who purchased the Company's common stock from 

November 12, 1998 through January 13, 1999, inclusive.  

Excluded from the Class are the defendants, members of the 

immediate families of the defendants, any entity in which any 

defendant has a controlling interest, and all of the 

subsidiaries, affiliates, legal representatives, heir, 

successors or assigns of any such excluded party.

          15.  Because millions of shares of the Company's 

common stock were purchased by the Class during the Class 

Period, the members of the Class are so numerous that joinder 

of all members is impracticable.  While the exact number of 

class members can only be determined by appropriate discovery, 

plaintiff believes that class members number in the thousands.  

They reside in various places in this country and throughout 

the world.

          16.  Plaintiff's claims are typical of the claims of 

the members of the Class.  Plaintiff and all members of the 

Class sustained damages as a result of defendants' wrongful 

conduct complained of herein.

          17.  Plaintiff will fairly and adequately protect the 

interests of members of the Class, and has retained counsel 

competent and experienced in class action and securities 

litigation.

          18.  A class action is superior to other available 

methods for the fair and efficient adjudication of this 

controversy.  The expenses and burdens of individual litigation 

would make it infeasible for the class members individually to 

seek redress for the wrongful conduct alleged.

          19.  Common questions of law and fact exist as to all 

members of the Class, and predominate over any questions 

affecting solely individual members of the Class.  Among the 

questions of law and fact common to the Class are:

               a.   whether the federal securities laws were 

violated by defendants' conduct as alleged herein;

               b.   whether defendants participated in and 

pursued the conduct complained of;

               c.   whether documents filed with the SEC and 

other documents, press releases and statements disseminated to 

the securities analysts, investing public, and the shareholders 

omitted and/or misrepresented material facts about the 

financial condition, business affairs, and prospects of the 

Company;

               d.   whether the defendants acted willfully or 

recklessly in omitting to state and/or misrepresenting material 

facts;

               e.   whether the market prices of AMD common 

stock during the Class Period were artificially inflated due to 

the nondisclosure and/or misrepresentations complained of 

herein;

               f.   whether the defendants perpetrated a fraud 

on the integrity of the market; and

               g.   whether the members of the Class have 

suffered damages and, if so, the proper measure of such 

damages.

          20.  Plaintiff knows of no difficulty which will be 

encountered in the management of this litigation which would 

preclude its maintenance as a class action.

                    SUBSTANTIVE ALLEGATIONS

          21.  As a player in the highly competitive 

microprocessor field, AMD operates in the shadows of the 

industry leader, Intel Corporation.

          22.  On October 26, 1998, AMD, faced with lagging 

demand for its microprocessors, slashed prices by nearly 30% in 

an effort to stimulate sales and increase its market share.

          23.  The price cut was an immediate hit with the 

financial community.  AMD's stock price surged from $17 7/16 

per share on October 26, 1998 (the day the price cuts were 

announced) to $22 9/16 per share on October 30.  As the 

Bloomberg news service reported on October 30, 1998, the stock 

price increase was based on optimism that an expected rise in 

personal computer sales during the 1998 holiday season would 

boost demand for AMD's K6 microprocessor.

          24.  Unbeknownst to investors, AMD could not 

reasonably expect to capitalize on the increased demand for its 

products in late 1998, because of serious design and production 

flaws that rendered the K6 incapable of performing at the 400 

megahertz or even 350 megahertz level, thereby seriously 

undermining the product's marketability.  As a result, AMD's K6 

sales during the fourth quarter were largely limited to the 300 

MHz version, which sells for less than half the price of the 

350 MHz version and less than one-third the price of the 400 

MHz version.

          25.  Despite these serious problems, defendants did 

nothing to dispel investors' expectations concerning the 1998 

fourth quarter (which was, by this time, well underway).

          26.  To the contrary, defendants took affirmative 

steps to fan the flames of investor delusion, thereby causing 

AMD's stock to trade at artificially inflated levels throughout 

the Class Period.

     27.  Thus, on November 9, 1998, AMD issued a press release 

on the Business Wire news line, in which the Company announced 

the signing of an agreement with Supercom, Inc. to distribute 

AMD's K6 processor.  Rather than acknowledge the design and 

production defects that plagued the K6, David Shefler, AMD's Vice 

President of Sales and Marketing for the Americas, gloated about 

the "growing success of the AMD K6 family of processor products."

     28.  On November 12, 1998, the Company held a conference at 

its Sunnyvale, California headquarters for its analysts.  At the 

meeting, according to Bloomberg reports, company executives made 

bullish projections concerning the number of K6 microprocessors 

they expected to sell in the fourth quarter, because of the 

strong demand for personal computers.   AMD's executives were 

reported in Bloomberg as having said that they expected AMD's 

share of the microprocessor market to rise as high as 14% in the 

fourth quarter (up from 12.4% in the third quarter and just 6.8% 

in the market in the first quarter).  One of the key participants 

at the November 12, 1998 conference was defendant Sanders.

     29.  Defendants' statements at this conference were 

misleading because of the failure to disclose then-existing 

design and production problems with AMD's K6 chip, which, unless 

corrected, would prevent AMD from taking advantage of the 

increased demand in the 1998 fourth quarter.  Unless the problem 

could be corrected, AMD's sales would be largely limited to 

slower (300 MHz) versions of the K6 (which sell for less than 

$80) as opposed to the faster, more profitable 350 to 400 MHz 

versions (which sell between $150 and $283).

     30.  On November 16, 1998, Dow Jones reported that AMD 

issued a press release touting the fact that the 400 MHz, 380 MHz 

and 366 MHz K6 processors would now carry 3dNow! technology.  

Investors were not informed that design problems precluded AMD 

from producing K6 processors at the above-referenced speeds (with 

or without 3dNow! technology).

     31.  According to a November 27, 1998 Dow Jones article, by 

the end of November 1998, securities analysts, even those who had 

long been bearish on AMD, began to be more upbeat about the 

Company's prospects, because of the Company's purported ability 

to sell and market the 400 megahertz K6-2 microprocessor for 

$283, well below Intel Corporation's comparable Pentium II chip.  

The Dow Jones article quoted analyst Thomas Kurlack of Merrill 

Lynch as saying, "because of good value of the K6-2, AMD has 

essentially created the sub-$1,000 PC market, and leading PC-

makers, including Compaq, IBM and Hewlett Packard, are 

experiencing strong growth with their AMD-based products."

     32.  Throughout the fourth quarter of 1998, AMD's stock 

continued to trade at artificially inflated levels because of 

continued reports that the expected year-end boom in personal 

computer sales had indeed come to fruition.  For example, 

Bloomberg reported on December 4, 1998 that "chip stocks have 

been gaining in recent weeks amid signs that holiday sales of 

personal computers are booming."  The article cited AMD as an 

example of this trend, as did a similar Bloomberg report issued 

on December 8, 1998.  Similarly, Bloomberg reported on 

December 22, 1998 that AMD was riding the effects of an industry-

wide increase in demand for microprocessors.  With no effort by 

the Company to quell the general industry-wide optimism or the 

statements made at the November 12 conference, the investing 

public pushed AMD's stock price to a Class Period high of $32 per 

share in early December 1998.

     33.  As the fourth quarter came to an end on December 31, 

1998, analysts and investors continued to express upbeat views 

concerning AMD, as they had been told nothing that would suggest 

that the rosy fourth quarter that the Company had spoken of a few 

weeks earlier had not come to pass.

     34.  Thus, Bloomberg reported on December 30, 1998 that 

shares of AMD rose amid optimism that strong sales of its 

microprocessors had boosted fourth quarter earnings.

     35.  That same day Dow Jones reported that BT Alex. Brown 

analyst, Erika Lauer, increased her fourth quarter earnings 

estimate for the Company, from $0.15 per share to $0.19 per 

share, due to "stronger than previously forecast unit demand for 

the Company's K6 family of microprocessors."  The article also 

reported that Fahnstock & Co. analyst, Dan Scoval, issued a $0.21 

EPS estimate due to recent industry strength.

     36.  It was not until after the close of trading on January 

13, 1999, more than two weeks after the Company's fourth quarter 

ended, that the Company disclosed for the first time that it had 

been unable to meet the growing demand in the fourth quarter due 

to production problems with the K6.  An AMD spokesman admitted 

that K6 chips not only failed to attain the hoped for 400 

megahertz standard, but they also failed to meet the next highest 

grade, 350 megahertz.  As a result, according to a January 18, 

1999 Dow Jones report, the microprocessors ended up running at 

just 300 megahertz, a speed that is considered "practically 

worthless" in today's personal computer market, and which sells 

for considerably less than the faster chips.  Because of the 

production problems, which led to lower than expected revenues, 

AMD reported earnings per share of $0.15, compared to the $0.19 

that analysts, on average, expected the Company to earn.

     37.  The reaction to this surprising news was swift and 

sudden.  AMD stock fell from $27 3/4 per share to just $22 1/2 

per share the day of this announcement, a single day decline of 

nearly 20%.

     38.  Moreover, in the aftermath of this announcement, the 

investment community was left in a state of confusion with 

respect to AMD.  According to a January 18, 1999 Dow Jones 

article, "several of Wall Street's finest were caught by 

surprise," by AMD's announcement.  The article quoted Piper 

Jaffrey analyst, Ashok Kumar, as saying, "I think AMD's 

management is sorely testing its credibility at this point."

        DEFENDANTS' MISREPRESENTATIONS PROXIMATELY CAUSED
     PLAINTIFF CLASS' DAMAGES THROUGH A FRAUD ON THE MARKET

     39.  At all relevant times, the market for AMD's securities 

was an efficient market which promptly digested current 

information with respect to the Company from all publicly-

available sources and reflected such information in the Company's 

stock price:  AMD's common stock met the requirements for 

listing, and was listed and actively traded, on the New York 

Stock Exchange ("NYSE"), the world's largest stock exchange and 

clearly a highly efficient market, and AMD filed periodic public 

reports with the SEC and the NYSE; AMD's stock was followed by 

analysts from major brokerages including BancBoston, NationsBank, 

Montgomery Securities, PaineWebber, Sutro & Co., Josephthal & 

Co., Needham & Co., Prudential, Fahnstock, Gruntal, and Piper 

Jaffrey.  The reports of these analysts were distributed to their 

customers and the public at large; and AMD regularly issued press 

releases which were carried by national newswires.

     40.  The material misrepresentations and omissions 

particularized in this complaint created an unrealistically 

positive assessment of the Company's business, finances and 

operations causing the market for its common stock to be over-

valued and artificially inflated.  This in turn proximately 

caused the damages complained of herein which were suffered by 

plaintiff and other members of the Class who relied on the 

integrity of the market price of the Company's common stock. 

                            COUNT I

             (Against AMD and the Defendant Sanders
        for Violations of Section 10(b) of the 1934 Act)

     41.  Plaintiff repeats and incorporates the allegations in 

the foregoing paragraphs as if fully set forth herein.

     42.  During the Class Period, the Company and the defendants 

issued releases, statements and reports which misrepresented the 

Company's business prospects and inflated the market price of the 

Company's common stock throughout the Class Period.  These 

reports contained untrue statements of material facts and omitted 

to state material facts necessary in order to make the statements 

made, not misleading, in violation of Section 10(b) of the 1934 

Act and Rule 10b-5, promulgated thereunder, as described above.

     43.  Defendants engaged in acts, practices and courses of 

business which operated as a fraud and deceit upon the plaintiff 

and the Plaintiff Class, and employed devices, schemes, and 

artifices to defraud and engaged in facts, practices, and a 

course of conduct in an effort to maintain artificially high 

market prices for the Company's common stock in violation of 

Section 10(b) of the 1934 Act and Rule 10b-5.

     44.  Defendants, by acting as described above, did so 

knowingly and intentionally or in such a reckless manner as to 

constitute a willful deceit and fraud upon the plaintiff and the 

Plaintiff Class.  They acted with scienter.  With knowledge or 

reckless disregard of the Company's true operating condition, 

defendants caused the statements to contain misstatements and 

omissions of material fact as alleged herein.

     45.  During the Class Period, defendants, individually and 

in concert, directly and indirectly, by the use, means or 

instrumentalities of interstate commerce and/or of the mails, 

engaged in an participated in a continuous course of conduct and 

conspiracy to circulate false and/or material information 

regarding the Company's sales and production.  Defendants 

employed devices, schemes and artifices to defraud, while in 

possession of material adverse non-public information, and 

engaged in acts, practices, and a course of conduct as alleged 

herein in an effort to assure investors of the Company's value 

and performance and results from prior operations.  This included 

the making of, or the participation in the making of, untrue 

statements of material facts and/or omitting to state material 

facts necessary in order to make the statements made about AMD 

and its business operations in light of the circumstances under 

which they were made, not misleading, as set forth more 

particularly herein, and engaged in transactions, practices and a 

course of business which operated as a fraud and deceit upon the 

purchasers of the Company stock during the Class Period. 

     46.  As a result of the materially false and misleading 

information and failure to disclose material facts, as set forth 

above, the market price of the common stock of AMD during the 

Class Period were artificially inflated.

     47.  In ignorance of the fact that the market price of the 

Company's publicly traded common stock and other securities were 

artificially inflated and distorted, and relying directly or 

indirectly on the false and misleading statements made by 

defendants, or upon the integrity of the market in which the 

securities trade, and the truth of any representations made to 

appropriate agencies and to the investing public, at the times at 

which any statements were made, and/or on the absence of material 

adverse information that was known to or recklessly disregarded 

by defendants but not disclosed in public statements by 

defendants during the Class Period, plaintiff and Plaintiff Class 

acquired the Company's securities during the Class Period at 

artificial prices and were damaged thereby.

     48.  At the time of said misrepresentations and/or 

omissions, plaintiff and other member of the Class were ignorant 

of their falsity, and believed them to be true.  Had plaintiff 

and the Plaintiff Class and the marketplace known of the truth 

concerning the Company's operations, plaintiff and the Plaintiff 

Class would not have purchased or otherwise acquired their AMD 

common stock during the Class Period or, if they had acquired the 

Company common stock during the Class Period they would not have 

done so at the artificially inflated prices at which they 

purchased their AMD stock during the Class Period.

     49.  By virtue of the foregoing, defendants have violated 

Section 10 (b) of the Exchange Act, and Rule 10b-5 promulgated 

thereunder.

     50.  As a direct and proximate result of defendants' 

wrongful conduct, plaintiff and the Plaintiff Class suffered 

damages in connection with their purchases of the Company's 

common stock during the Class Period.

                            COUNT II

                   (Against Defendant Sanders
        for Violation of Section 20(a) of the 1934 Act)

     51.  The plaintiff repeats and incorporates the allegations 

in the foregoing paragraphs as if fully set forth herein.

     52.  Because of his executive position with AMD, defendant 

Sanders had access to the adverse confidential and material 

information about the Company's sales and production and approved 

the misleading statements and omissions as particularized herein 

and acted to conceal them.  Defendant Sanders because of his 

position of control and authority as a principal executive 

officer of the Company, was able to and did, directly or 

indirectly, control the content of the Company's various publicly 

disseminated reports, press releases and statements.  Defendant 

Sanders had and exercised the power and influence to cause the 

Company to engage in the illegal practices complained of herein.  

Any acts attributed to AMD were caused and/or influenced by 

defendant Sanders by reason of his domination and control of the 

Company.

     53.  As an officer of a publicly held Company, defendant 

Sanders had a duty to disseminate accurate and truthful 

information with respect to the Company's business, operations 

and financial performance so that the market price of the 

Company's securities would be based on truthful, accurate and 

timely disclosure of all material information.

     54.  Defendant Sanders was a controlling person of the 

Company within the meaning of Section 20 (a) of the 1934 Act and 

pursuant to said Section 20 (a) is liable for AMD's violations of 

Section 10 (b) of the 1934 Act and Rule 10b-5 promulgated 

thereunder.

                          JURY DEMAND

     55.  Plaintiff demands a trial by jury.

                       PRAYER FOR RELIEF

     WHEREFORE, the plaintiff demands judgment against the 

defendants, and each of them jointly and severally, as follows;

          a.   Determining that this suit is a proper plaintiff 

class action and certifying the plaintiff and Plaintiff Class 

representative pursuant to Rule 23 of the Federal Rules of Civil 

Procedure;

          b.   Declaring that the defendants violated the federal 

securities laws, as alleged herein;

          c.   Awarding the plaintiff and the Class damages as a 

result of the violations set forth in this complaint, with 

interest thereon;

          d.   Awarding the plaintiff and the Class the costs and 

disbursements of this action, including reasonable attorneys' 

fees, as well as costs and fees paid to accountants and other 

experts; and

          e.   Granting such other and further relief as the Court 

may deem just and proper.

Dated:  March 9, 1999

                              Respectfully submitted,

                              LAW OFFICES OF LIONEL Z. GLANCY


                              By:____________________________
                                   LIONEL Z. GLANCY #134180
                                   TRACY L. THROWER #145782
                                   MICHAEL GOLDBERG #188669

                              1801 Avenue of the Stars
                              Suite 308
                              Los Angeles, California  90067
                              (310) 201-9150


                              IRA M. PRESS, ESQ.
                              KIRBY McINERNEY & SQUIRE, LLP
                              830 Third Avenue
                              10th Floor
                              New York, New York  10022
                              (212) 317-2300
                              Attorneys for Plaintiff


 

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