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Shareholder's Class Action Complaint

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Title:

Shareholder's Class Action Complaint

Entities:

Mcafee, Inc.

Date:

2002

Size:

Preview shows 3KB of 10KB total

Price:

$39

ID:

#1267888

► Legal ► Pleadings ► Complaints ► Class Action ► Shareholder Class Action Complaints

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               IN THE COURT OF CHANCERY IN THE STATE OF DELAWARE

                          IN AND FOR NEW CASTLE COUNTY





---------------------------------------



ADRIAN CHIN,



                    Plaintiff,                    Civil Action No. 19484NC





             - against -





MCAFEE.COM CORP., SRIVATS SAMPATH,

GEORGE SAMENUK, STEPHEN C. RICHARDS,

RICHARD M. SCHELL, FRANK C. GILL

and NETWORK ASSOCIATES INC.



                    Defendants.



---------------------------------------





                      SHAREHOLDER'S CLASS ACTION COMPLAINT

                      ------------------------------------



          Plaintiff, by his attorneys, for his complaint against defendants,

alleges upon personal knowledge with respect to paragraph 2, and upon

information and belief based, inter alia, upon the investigation of counsel, as

to all other allegations herein, as follows:



                              NATURE OF THE ACTION

                              --------------------



          1.  This is a stockholder's class action on behalf of the public

stockholders of McAfee.com Corp. ("The McAfee" or the "Company") to enjoin the

proposed acquisition of the publicly owned shares of McAfee's common stock by

its controlling shareholder, defendant Network Associates Inc. ("Network").



<PAGE>

                                  THE PARTIES

                                  -----------





     2.  Plaintiff has been the owner of the common stock of the Company since

prior to the transaction herein complained of and continuously to date.



     3.  Defendant McAfee is a corporation duly organized and existing under the

laws of the State of Delaware.



     4.  Defendant Network is a corporation duly organized and existing under

the laws of Delaware. Network owns approximately 75% of the Company's

outstanding common stock.



     5.  Defendant George Samenuk is a director of the Company. He is also Chief

Executive Officer and Chairman of the Board of Network.



     6.  Defendant Stephen C. Richards is a director of the Company. He is also

Chief Financial Officer and COO of Network.



     7.  Defendant Srivats Sampath is Chairman of the Board and Chief Executive

Officer of the Company.



     8.  Defendant Frank C. Gill is a director of the Company.



     9.  Defendant Richard M. Schell is a director of the Company.



    10.  The defendants named in paragraphs 5 through 9 (the "Individual

Defendants") are in a fiduciary relationship with plaintiff and the other public

stockholders of McAfee and owe them the highest obligations of good faith and

fair dealing.

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