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  1. The plaintiffs assert claims against Jabil Circuit, Inc., ("Jabil") and sixteen individual defendants (collectively, the "defendants") pursuant to sections 10(b), 14(a), 20(a), and 20A of the Securities Exchange Act of 1934 (the "Exchange Act"), and Securities and Exchange Rules 10b-5 and 14a-9. 75) to dismiss the amended complaint (the "complaint") (Doc. Appointed the lead plaintiffs in a January 18, 2007, order (Doc. Main ("Main") served as the company's chief executive officer and president and as a director. The defendants included the APB representation in each Form 10-K for fiscal years 2001 through 2005. 73, ¶¶ 106, 110, 112-14, 125, 128, 137, 139) The plaintiffs allege the APB 25 representation is false and misleading because the defendants failed to record the appropriate compensation expense for backdated options. 73, ¶¶ 106, 110, 112-13, 125, 137) The plaintiffs allege the materiality of the failure to record. 73, ¶¶ 214-17) The plaintiffs allege that throughout the class period the defendants falsely and misleadingly stated in each Form 10-K Jabil's quarterly and annual earnings. 73, ¶¶ 106, 110, 122-25, 131-33, 136-37, 149) The plaintiffs allege that each financial statement is false and misleading because Jabil "failed to record material amounts of compensation expense in accordance with APB Opinion No. 73, ¶¶ 106, 110, 122-25, 131-33, 136-37, 149) The plaintiffs allege that the granting of backdated options required Jabil to record a compensation expense. 73, ¶¶ 100, 104, 109, 115, 127) Each false financial statement allegedly enabled Jabil to meet its projection forecast and "caused Jabil's stock price to be artificially inflated, allowing the defendants to pocket huge insider trading profits on top of exercising and selling retroactively priced stock options for millions of dollars" and "to reap millions of dollars in incentive based bonuses (¶¶ 53-68) for meeting and exceeding profitability goals." (Doc.

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