22.  Plaintiff brings this action as a class action pursuant to Rule 23 of the Federal Rules  of Civil Procedure on behalf of all persons and entities that own ShoreTel common stock (the  “Class”).  Excluded from the Class are defendants and their affiliates, immediate families, legal  representatives, heirs, successors or assigns and any entity in which defendants have or had a  controlling interest.   23.  Plaintiff’s claims are properly maintainable as a class action under Rule 23 of the  Federal Rules of Civil Procedure.   90.  Plaintiff repeats all previous allegations as if set forth in full.   91.  Defendants have caused the Recommendation Statement to be issued with the  intention of soliciting ShoreTel stockholders to tender their shares in the Tender Offer.   92.  Section 14(d)(4) of the Exchange Act and SEC Rule 14d-9 promulgated thereunder  require full and complete disclosure in connection with tender offers.   93.  The Recommendation Statement violates Section 14(d)(4) and Rule 14d-9 because it  omits material facts, including those set forth above, which omission renders the Recommendation  Statement false and/or misleading.   96.  Plaintiff repeats all previous allegations as if set forth in full.   97.  Defendants violated Section 14(e) of the Exchange Act by issuing the  Recommendation Statement in which they made untrue statements of material facts or failed to state  all material facts necessary in order to make the statements made, in light of the circumstances  under which they are made, not misleading, or engaged in deceptive or manipulative acts or  practices, in connection with the Tender Offer.   98.  Defendants knew that Plaintiff would rely upon their statements in the  Recommendation Statement in determining whether to tender her shares pursuant to the Tender  Offer.   Class Claims Against All Defendants for  Violations of Section 14(e) of the Exchange Act   Class Claims Against All Defendants for Violations of   Section 14(d) of the Exchange Act And SEC Rule 14d-9   Company Background  