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20 21 22 24 25 26 28 1 Plaintiff David Kinney (“Plaintiff”), by and through his attorneys, alleges the :15-cv-08914-DMG-RAO Document 1 Filed 11/16/15 Page 2 of 47 Page ID #:2 2 following upon information and belief, except as to those allegations concerning 3 Plaintiff, which are alleged upon personal knowledge. Plaintiff’s information and 4 5 6 without limitation: (a) review and analysis of regulatory filings made by Capstone 7 8 9 10 releases and media reports issued by and disseminated by Capstone; and (c) review 11 12 13 14 15 16 17 18 “Exchange Act”). 19 belief is based upon, among other things, his counsel’s investigation, which includes Turbine Corp. (“Capstone” or the “Company”), with the United States (“U.S.”) Securities and Exchange Commission (“SEC”); (b) review and analysis of press of other publicly available information concerning Capstone. NATURE OF THE ACTION AND OVERVIEW 1. This is a class action on behalf of purchasers of Capstone securities between November 7, 2013 and November 5, 2015, inclusive (the “Class Period”), seeking to pursue remedies under the Securities Exchange Act of 1934 (the 2. Capstone develops, manufactures, markets and services microturbine technology solutions for use in stationary distributed power generation applications, including cogeneration (combined heat and power, integrated combined heat and 23 power, and combined cooling, heat and power), renewable energy, natural resources and critical power supply. In addition, the Company’s microturbines can be used as battery charging generators for hybrid electric vehicle applications. Microturbines 27 can purportedly produce power on-site in parallel with the electric grid or stand CLASS ACTION COMPLAINT 1PDF Image | CLASS ACTION COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS
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