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2007. Plaintiff says that during the Class Period, Simon made and/or was responsible

for numerous materially false and misleading statements and omissions in Whitney’s

SEC filings, press releases, conference calls with analysts, and on the Company’s

website. Simon also signed the Company’s SEC filings, including but not limited to

Whitney’s Forms 10-Q and Form 10-K and the Registration Statements filed with the

SEC in connection with the Company’s PIPE Registration in November 2006 and its

aborted spin-off Registration of EduTrades. During the Class Period, Simon liquidated

over $911,999 worth of his personally-held Whitney common stock. See CAC at ¶ 6.

Defendant Alfred R. Novas (“Novas”) was, during the Class Period, Chief

Financial Officer of the Company from at least January 25, 2006. Plaintiff says that

Novas made and/or was responsible for materially false and misleading statements

and omissions in Whitney’s SEC filings, press releases, conference calls with analysts,

and on the Company’s website. Novas also signed the Company’s SEC filings,

including but not limited to Whitney’s Form(s) 10-Q and Form 10-K and the Registration

Statements filed with the SEC in connection with the Company’s aborted spin-off

Registration of EduTrades. See CAC at ¶ 7.

Defendant John F. Kane (“Kane”) was, during the Class Period, Executive

Vice President of Operations for the Company. Plaintiff says that Kane made and/or

was responsible for materially false and misleading statements and omissions in

Whitney’s SEC filings, press releases, conference calls with analysts, and on the

Company’s website, including but not limited to Whitney’s Forms 10-Q and Form 10-K

and the Registration Statements filed with the SEC in connection with the Company’s

6

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