EXHIBIT A 

Case 1:07-cv-03455-RJH Document 18-3 Filed 07/17/2007 Page 1 of 9
KAHN GAUTHIER SWICK, LLC 

Michael A. Swick (MS-9970) 

Kim E. Miller (KM-6996) 

12 East 41st Street, 12th Floor 

New York, NY 10017 

Telephone: (212) 696-3730 

Fax: (504) 455-1498 

KAHN GAUTHIER SWICK, LLC 

Lewis S. Kahn 

650 Poydras Street, Suite 2150 

New Orleans, LA 70130 

Telephone: (504) 455-1400 

Fax: (504) 455-1498 

Counsel for the Chen Group and 

Proposed Lead Counsel for the Class 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

BRICKMAN INVESTMENTS, INC., 

Individually And On Behalf of All Others 

Similarly Situated, 

 Plaintiff, 

 vs. 

ALLOT COMMUNICATIONS, LTD., YIGAL 

JACOBY, RAMI HADAR AND ADI SAPIR,

 

 Defendants. 

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DOCKET NUMBER: 07-cv-3455 

HON. RICHARD J. HOLWELL 

(Caption continued on the following page) 

JOINT DECLARATION OF CHEN GROUP MEMBERS SHICHAO CHEN, CYNTHIA 

HOBER AND ROBERT JONKHEER IN FURTHER SUPPPORT OF THE MOTION OF 

THE CHEN GROUP TO CONSOLIDATE RELATED ACTIONS; TO BE APPOINTED 

LEAD PLAINTIFF; AND TO APPROVE PROPOSED LEAD PLAINTIFF’S CHOICE 

OF COUNSEL 

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GERALD BILGER, Individually And On Behalf 

of All Others Similarly Situated, 

 

 Plaintiff, 

 vs. 

ALLOT COMMUNICATIONS, LTD., YIGAL 

JACOBY, RAMI HADAR AND ADI SAPIR,

 

 Defendants. 

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DOCKET NUMBER: 07-cv-3815 

HON. RICHARD J. HOLWELL 

ELIYAHU MOKHTAR, Individually And On 

Behalf of All Others Similarly Situated, 

 

 Plaintiff, 

 vs. 

ALLOT COMMUNICATIONS, LTD., YIGAL 

JACOBY, RAMI HADAR AND ADI SAPIR,

 

 Defendants. 

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DOCKET NUMBER: 07-cv-5456 

HON. RICHARD J. HOLWELL 

SHANNON VINSON, Individually And On 

Behalf of All Others Similarly Situated, 

 

 Plaintiff, 

 vs. 

ALLOT COMMUNICATIONS, LTD., YIGAL 

JACOBY, RAMI HADAR AND ADI SAPIR,

 

 Defendants. 

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DOCKET NUMBER: 07-cv-5457 

HON. RICHARD J. HOLWELL 

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Allot Communications, Ltd.. (“Allot”) investors Shichao Chen, Cynthia Hober and 

Robert Jonkheer (members of the “Chen Group”) hereby declare as follows: 

 1. We submit this joint declaration in further support of our motion for appointment 

as Lead Plaintiff and for approval of selection of Lead Counsel, pursuant to the Private Securities 

Litigation Reform Act of 1995 (“PSLRA”). 

2. I, Shichao Chen, hold a B.S. degree in computer science from Beijing University 

and a Masters degree in business management from the University of Surrey, U.K. I am 

a professional service engineer in a multinational information technology company. I manage 

my own portfolio and invested in Allot stock. 

3. I, Cynthia Hober, hold a B.A. in Liberal Arts, with a minor in microbiology, from 

the University of Maryland. I have been a workers’ compensation claims specialist for the past 

20 years. I manage my own portfolio and invested in Allot stock. 

4. I, Robert Jonkheer, am retired. I worked for over 43 years in the computer

industry in various positions. I manage my own portfolio and invested in Allot stock. 

 5. I have no interests antagonistic to those of the Class and I do not believe that I am 

subject to any unique defenses. 

6. I understand that I am seeking to be appointed as the lead plaintiff as part of a 

small, cohesive, manageable three member group that, if appointed as lead plaintiff, will work 

together, and direct the activities of our chosen counsel, Kahn Gauthier Swick, LLC (“KGS”), in 

the prosecution of this action. The Chen Group believes that our collective and shared 

knowledge gained through investing in Allot shares will assist counsel in prosecution of this 

action on behalf of the Class, and that the group’s differing experiences and expertise will 

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provide a broad perspective to the decision-making process in this action. Taken together, I 

believe the Chen Group will provide fair and adequate representation of the Class. 

7. I understand that to fulfill the group’s fiduciary duties and obligations as lead 

plaintiff, I must fairly and adequately represent the Class by vigorously prosecuting this case on 

behalf of the Class, as part of the Chen Group. 

8. I understand my responsibilities as lead plaintiff and will fulfill these 

responsibilities to the best of my ability. I further understand that as lead plaintiff, the Chen 

Group will have the final responsibility for supervising its counsel and for making important 

litigation decisions. To that extent, the Chen Group intends to oversee its counsel and monitor 

the progress of the litigation to discharge its duties to the Class. In discharging those duties, it 

will, among other things, review pleadings and motions papers; obtain regular status reports on 

the progress of the litigation on developments in the action; potentially produce documents, 

answering interrogatories, and/or sitting for a deposition; and have input into litigation decisions 

and strategies, and involvement in the final approval of any major litigation decisions, including 

whether or not to settle the litigation and, if so, for how much. 

9. As a member of this small, cohesive group, I intend to work closely and 

cooperatively with the other members of the group, to oversee the litigation in a manner intended 

to best vindicate the interests of all Class members. As a member of the Chen Group, I have 

communicated with the other member of the group, and feel strongly that we, as a group, can 

effectively and efficiently prosecute this action together. We will do so by, among other means, 

communicating, individually or as a group, with each other and with counsel, to the extent we 

determine necessary to fairly and adequately represent the interests of the Class. 

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10. We intend to continue to regularly communicate with our counsel and with each 

other, as we have done thus far, through the use of email, Internet and/or telephone. As proposed 

lead plaintiffs, we have agreed upon how we will make decisions and will endeavor to make all 

decisions unanimously, or where unanimity is not possible, the group has agreed to defer to 

Shichao Chen, as its spokesperson, based upon his large losses, educational and business 

experience. Based on our communications to date, however, I do not foresee a circumstance 

where the members of our group could not reach a mutually agreeable solution to any issue that 

might arise. 

11. The group has selected Shichao Chen to serve as the Chen Group’s spokesperson 

and liaison with counsel and the Court. Although I understand that emergencies rarely arise in 

the course of litigation of this nature that would not permit sufficient time for our group to be 

consulted, particularly in light of modern technological means of communication, to the extent 

such an emergency arises and our group is unable to meet together in sufficient time to 

collectively make a decision, Shichao Chen will be responsible for making such decisions. 

12. Additionally, I understand that our group will meet regularly—most often by 

telephonic conference—to discuss the progress of the litigation and to approve litigation 

strategies recommended by our counsel. The Chen Group anticipates those meetings will occur 

as often as necessary, depending on the activity in the case. The Chen Group also anticipates 

some of those meetings will be without counsel attending in order for the group to discuss 

counsel’s recommendations and performance amongst ourselves. The Chen Group understands 

that litigation of this nature has active and inactive periods, and each member will make 

themselves available, as needed to fulfill its role as lead plaintiff. 

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