The Complaint charges that Syntax-Brillian Corp., a designer, developer and distributor of high definition televisions (HDTVs) in liquid crystal display (LCD) and liquid crystal silicon (LCoS) formats, has reported explosive growth due largely to reportedly increased sales to a Chinese distributor South China House of Technology (``SCHOT''). Throughout 2007, up to late August 2007, the Company and defendants have been issuing a series of increasing bullish statements about the Company's sales and revenues and prospects and also selling stock on two occasions (May 2007 and August 2007) in the midst of the bullish revenue and profit guidance statements. The statements served their purpose: Syntax stock price was buoyed by these statements in the $6-$7 range allowing Syntax to sell hundreds of millions of dollars of stock. On September 13, 2007, after disclosure of previously concealed omitted facts, including a failure of adequate accounting systems and an approximately 35% shortfall in previously anticipated revenues, the price of Syntax stock fell over 30% causing loss and damage to all purchasers of Syntax stock on the open market.