SUPPLEMENT
TO
eVISION USA.COM, INC.
PROSPECTUS
DATED AUGUST 14, 2000
On or about September 8, 2000, Michael Halperin, M.D., and Donald Kern,
D.D.S., filed a Complaint in the United States District Court for the Southern
District of New York (Case No. 00 CIV. 6769) against eVision USA.Com, Inc.,
eBankerUSA.com, Inc., a partially owned subsidiary of eVision, and American
Fronteer Financial Corporation, a wholly owned broker-dealer subsidiary of
eVision, Fai Chan, Tong Wan Chan, Robert Trapp, Kwok Jen Fong, David Chen, Gary
Cook, Jeffrey Bush and Robert Jeffers, Jr., officers and/or directors of eVision
and eBanker.
In their Complaint, the plaintiffs state that the action is a class action
brought by them on behalf of purchasers of securities of eBanker and eVision,
through American Fronteer and other securities firms, between April 1998 and
August 2000.
The Complaint alleges that the documents pursuant to which eBanker and
eVision issued securities, American Fronteer sold the securities, communications
with their shareholders and public filings by eVision misrepresented and/or
failed to disclose material facts about the business, management, services,
sales obligations, markets, financial condition, use of private offering
proceeds, registration plans and future business prospects of eBanker and
eVision. The Complaint alleges violations of Section 10(b) and Rule 10b-5 and
Section 20(a) under the Securities Exchange Act of 1934, of Sections 11 and
12(2) under the Securities Act of 1933 and of the common law of New York. The
Complaint also alleges breach of fiduciary duty and corporate waste against the
eBanker and eVision officer defendants and that the two eBanker offerings should
be integrated.
The plaintiffs request that the lawsuit be maintained as a class action and
that they be certified as representatives of the class, that compensatory
damages be awarded against defendants in an amount of not less than $70,000,000
plus interest; that they be awarded exemplary and punitive damages pursuant to
their claims of fraud and breach of fiduciary duty; that the defendant companies
correct any misstatements and otherwise provide full disclosure of all material
facts concerning the companies; that eBanker distribute to certain class
plaintiffs the same securities as offered to certain other class members; that
eBanker make rescission offers to certain class members; and such other relief
as the Court may deem just and proper.
The plaintiffs have requested a jury trial.
The defendant companies have reviewed the numerous allegations contained in
the Complaint, believe the allegations are without merit and intend to
vigorously defend against the allegations. One or more defendants are also
considering filing counterclaims against the plaintiffs.
On or about September 15, 2000, eBanker filed a Complaint in the District
Court, City and County of Denver, Colorado (Case No. 00 CV 6942) against Michael
Halperin. In its Complaint, eBanker alleges that Dr. Halperin intentionally
interfered with prospective economic relations of eBanker by deterring
investments in eBanker and delaying eBanker's initial public offering by making
false written and verbal statements about eBanker and its management because
eBanker declined to invest in projects suggested by Dr. Halperin. eBanker also
alleges that Dr. Halperin slandered eBanker by knowingly making false statements
against eBanker. eBanker requests that the Court grant eBanker actual and
special damages, including lost profits, in an amount to be determined at trial.
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Specifically, the Complaint alleges that the defendant proposed that
eBanker make an investment in a restaurant franchise and proposed that eBanker
participate with a bank to issue secured credit cards financed by eBanker. The
Complaint alleges that eBanker negotiated with two friends of defendant
regarding the investment in the restaurant franchise and that the defendant
expected to be paid a commission in connection with the credit card transaction.
eBanker determined that the investment in the restaurant franchise was too risky
and that the bank had no experience in issuing secured credit cards. The
Complaint also alleges that when eBanker did not make the investment or enter
into an agreement with the bank, the defendant deterred future investments in
eBanker by making false accusations against eBanker and its management.
The Complaint also alleges that the defendant's actions delayed eBanker's
initial public offering.
eBanker has requested a jury trial.
The date of this Supplement is September 20, 2000.
