IBM Class Action Submission Form

The filed complaint alleges that International Business Machines Corporation made materially false and/or misleading statements and/or failed to disclose that:

(i) Strategic Imperatives Revenue growth, CAMSS (the distinct components of “Cloud,” “Analytics,” “Mobile,” “Security,” and “Social”) and CAMSS Components’ revenue growth, and the Company’s Segments’ revenue growth were artificially inflated as a result of the wrongful reclassification/misclassification of revenues from non-strategic to strategic to make those revenues eligible for treatment as Strategic Imperatives Revenue; and (ii) IBM was materially less successful in growing its Strategic Imperative business, reporting materially higher growth than it actually achieved only by wrongfully reclassifying and misclassifying revenue from non-strategic to strategic thereby reporting publicly materially false Strategic Imperative Revenue.