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Between 20, the suit claims, Dell made drastic and painful cuts in its production and service operations, leading to a marked decline in quality and a sharp reversal of customer opinion of its service.

Frequently, the complaint cites the notorious problem with the exploding batteries in Dell notebooks (batteries manufactured by Sony), as evidence that Dell failed to implement the types of quality controls over its production line that were once critical to the company's original "Dell Direct" business model.

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The suit alleges Intel provided Dell with rebates knowing full well how Dell intended to report the revenues.

However, it's important to note that the suit claims Dell did report the revenue, not that it failed to do so.

The suit alleges that Dell executives used false information to help inflate their stock value, then used backdated options to purchase shares prior to their decline in value.

Though the suit does not state this explicitly, apparently the shares purchased through exercising options were among those the executives then sold again in massive quantity.

For any normal company, the downturn in customer appreciation and satisfaction, coupled with higher costs associated with addressing warranty issues, would lead to reduced revenues, which would then probably trigger stock price declines.

But Dell padded those losses, the class-action suit alleges, using revenues gained from Intel rebates for Dell's having purchased its processors exclusively during that period, and not AMD's.

During that period, Dell executives cashed in about 98.9 million shares of stock, for what the plaintiff's accountants quantify as .32 billion in total value distributed to company executives.

What the lawsuit does not address, however, is how much Dell stock value would have been worth had the alleged misdeeds not been done, and had Dell been more forthcoming about the allegedly true reasons for its downturn in revenues.

Many executives, the suit details, sold off between 90% and 100% of their personal stock holdings, with Rollins allegedly selling 98.6% of his personal holdings in Dell Computer - figures such as this were not attributed and have not been verified.

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