(Against All Defendants For Violations of   Section 10(b) And Rule 10b-5 Promulgated Thereunder)   (Violations of Section 20(a) of the  Exchange Act Against The Individual Defendants)   21.  Juniper designs, develops, and sells products and services that together provide its  customers with a high-performance network infrastructure built on simplicity, security, openness, and  scale.  The Company serves the high-performance networking requirements of global service providers,  enterprises, governments, and research and public sector organizations.  The Company’s core  competencies are in hardware systems, silicon design, network architecture.  Materially False and Misleading  Statements Issued During the Class Period   22.   On April 24, 2012, the Company issued a press release announcing its financial results  for the first quarter ended March 31, 2012.  For the quarter, the Company reported net income of $16.3  million, or $0.03 diluted earnings per share (“EPS”) and total net revenues of $1 billion, compared to  net income of $129.8 million or $0.24 diluted EPS and total net revenues of $1.1 billion for the same  period a year ago.   23.  On May 9, 2012, the Company filed a quarterly report for the period ended March 31,  2012 on a Form 10-Q with the SEC signed by Defendants Denholm and Zamiska, which reiterated the  Company’s previously reported financial results and financial position.  In addition, the Form 10-Q  contained signed certifications pursuant to the Sarbanes-Oxley Act of 2002 (“SOX”) by Defendants  Johnson and Denholm stating that the financial information contained in the Form 10-Q was accurate,  and disclosed any material changes to the Company’s internal control over financial reporting.   24.  On July 24, 2012, the Company issued a press release announcing its financial results for  the second quarter ended June 30, 2012.  For the quarter, the Company reported net income of $57.7  million, or $0.11 diluted EPS and total net revenues of $1.1 billion, compared to net income of $115.6  million or $0.21 diluted EPS and total net revenues of $1.1 billion for the same period a year ago.  Case3:13-cv-03733-WHO   Document1   Filed08/12/13   Page5 of 20 36.  The statements referenced in ¶¶ 21 - 34 above were materially false and/or misleading  because they misrepresented and failed to disclose the following adverse facts, which were known to  defendants or recklessly disregarded by them, including that: (1) the Company was violation of the U.S.  Foreign Corrupt Practices Act (“FCPA”); (2) the Company’s reported revenues were derived in part  from violations of the FCPA; (3) the Company lacked effective internal controls over financial  Case3:13-cv-03733-WHO   Document1   Filed08/12/13   Page9 of 20 39.  Plaintiff brings this action as a class action pursuant to Federal Rule of Civil Procedure  23(a) and (b)(3) on behalf of a Class, consisting of all those who purchased or otherwise acquired  Juniper securities during the Class Period (the “Class”); and were damaged thereby.  Excluded from the  Class are defendants herein, the officers and directors of the Company, at all relevant times, members  of their immediate families and their legal representatives, heirs, successors or assigns and any entity in  which defendants have or had a controlling interest.   40.  The members of the Class are so numerous that joinder of all members is impracticable.   Throughout the Class Period, Juniper securities were actively traded on the NYSE.  While the exact  number of Class members is unknown to Plaintiff at this time and can be ascertained only through  appropriate discovery, Plaintiff believes that there are hundreds or thousands of members in the  proposed Class.  Record owners and other members of the Class may be identified from records  maintained by Juniper or its transfer agent and may be notified of the pendency of this action by mail,  using the form of notice similar to that customarily used in securities class actions.  Case3:13-cv-03733-WHO   Document1   Filed08/12/13   Page10 of 20 47.  Plaintiff repeats and realleges each and every allegation contained above as if fully set  forth herein.   48.  This Count is asserted against defendants and is based upon Section 10(b) of the  Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5 promulgated thereunder by the SEC.   49.  During the Class Period, defendants engaged in a plan, scheme, conspiracy and course of  conduct, pursuant to which they knowingly or recklessly engaged in acts, transactions, practices and  courses of business which operated as a fraud and deceit upon Plaintiff and the other members of the  Class; made various untrue statements of material facts and omitted to state material facts necessary in  Case3:13-cv-03733-WHO   Document1   Filed08/12/13   Page12 of 20 57.  Plaintiff repeats and realleges each and every allegation contained in the foregoing  paragraphs as if fully set forth herein.   58.  During the Class Period, the Individual Defendants participated in the operation and  management of Juniper, and conducted and participated, directly and indirectly, in the conduct of  Juniper’s business affairs.  Because of their senior positions, they knew the adverse non-public  information regarding Juniper’s FCPA violations.     59.  As officers and/or directors of a publicly owned company, the Individual Defendants had  a duty to disseminate accurate and truthful information with respect to Juniper’s financial condition and  results of operations, and to correct promptly any public statements issued by Juniper which had  become materially false or misleading.   60.  Because of their positions of control and authority as senior officers, the Individual  Defendants were able to, and did, control the contents of the various reports, press releases and public  filings which Juniper disseminated in the marketplace during the Class Period concerning Juniper’s  results of operations.  Throughout the Class Period, the Individual Defendants exercised their power  and authority to cause Juniper to engage in the wrongful acts complained of herein. The Individual  Defendants therefore, were “controlling persons” of Juniper within the meaning of Section 20(a) of the  Case3:13-cv-03733-WHO   Document1   Filed08/12/13   Page15 of 20 AFFILIATES MUST SUBMITTED FOR PROPER APPROVAL.   Background  