David Stern Securities Class Action

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDAFORT LAUDERDALE DIVISIONSTAN COOPER and NEERAJ METHI,Individually and On Behalf of All Others Similarly Situated,Plaintiffs,v.DJSP ENTERPRISES, INC; DAVID J. STERN;and KUMAR GURSAHANEY,Defendants.)))))))))))))CASE NO.:CLASS ACTION

COMPLAINT FOR VIOLATIONS OFTHE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIALPlaintiffs Stan Cooper and Neeraj Methi, by and through their attorneys, allege thefollowing upon information and belief, except as to those allegations concerning Plaintiffs,which are alleged upon personal knowledge. Plaintiffs’ information and belief is based upon,among other things, the investigation of Plaintiffs’ counsel, which includes without limitation:(a) review and analysis of regulatory filings made by DJSP Enterprises, Inc. (“DJSP” or the“Company”) with the United States Securities and Exchange Commission (“SEC”); (b) reviewand analysis of press releases and media reports issued by and disseminated by DJSP; and(c) review of other publicly available information concerning DJSP.

NATURE OF THE ACTION AND OVERVIEW

1.

This is a securities class action filed on behalf of purchasers of DJSP’s securitiesbetween March 16, 2010 and May 27, 2010, inclusive (the “Class Period”), seeking to pursueremedies under the Securities Exchange Act of 1934 (the “Exchange Act”).

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2.

DJSP is one of the largest providers of processing services for the mortgage andreal estate industries in Florida and the United States. Through its three operating subsidiaries,the Company provides non-legal services that are ancillary to and support the residential realestate foreclosure market, other related legal actions and lender owned real estate (“REO”)services. These services are provided almost exclusively to the Law Offices of David J. Stern(“DJS”), which provides residential foreclosure work for approximately 12 loan servicing firms.DJS’s clients include all of the top 10 and 17 of the top 20 mortgage servicers in the US.Consequently, DJSP provides its services to these same mortgage servicers through anagreement between DJSP and DJS.3.

DJS is a law firm founded and solely owned by David J. Stern (“Stern”), who isalso the President and Chief Executive Officer (“CEO”) of DJSP. According to the Company’sForm 20-F filed with the Securities and Exchange Commission (“SEC”) on April 2, 2010, DJS isthe Company’s primary client and any change in the volume of foreclosures referred to DJS byits clients would necessarily and materially affect the financial performance of DJSP.4.

On March 16, 2010, DJSP filed a 6-K with the SEC in which it touted thequarterly results it announced on March 11, 2010, reaffirmed its previously-announced guidance,and also indicated that no matter what the Obama Administration does to slow downforeclosures, they have found the “way to create a profit center on it. . . .”5.

In April 2010 one of DJS’s largest clients began a foreclosure system conversionthat resulted in a substantial decrease in the volume of foreclosures referred to DJS for April andMay 2010. This was significant because DJSP relied heavily on the providing of ancillaryservices to DJS to generate its revenue. Despite knowing that DJSP generates a significantamount of its revenue from flat fees earned within the first month of a referral and that any

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significant decrease in referrals would materially and adversely affect its revenues, DJSP did notpublicly disclose the substantial slowdown in foreclosure referrals or the slowdown due togovernmental intervention programs until May 27, 2010.6.

The adjusted closing price for DJSP shares on May 27, 2010 was $8.87 per shareon a volume of 412,500 shares trading. Trading of DJSP shares opened on May 28, 2010 at$6.33 per share and closed at an adjusted price of $6.38 per share on a volume of 4,931,300,representing a drop of nearly 29%. As of April 2, 2010, the Company had 9,166,666 sharesoutstanding; thus approximately 54% of the Company’s outstanding shares were tradedfollowing the revelation on May 27, 2010 that there would be a substantial decrease in thenumber of residential foreclosure cases to DJS and subsequently to DJSP.7.

As a result of Defendants’ wrongful acts and omissions, and the precipitousdecline in the market value of the Company’s securities, Plaintiffs and other Class Membershave suffered significant losses and damages.

JURISDICTION AND VENUE

8.

The claims asserted herein arise under and pursuant to Sections 10(b) and 20(a) of the Exchange Act, (15 U.S.C. §§78j(b) and 78t(a)), and Rule 10b-5 promulgated thereunder(17 C.F.R. §240.10b-5).9.

This Court has jurisdiction over the subject matter of this action pursuant toSection 27 of the Exchange Act (15 U.S.C. §78aa) and 28 U.S.C. §1331.10.

Venue is proper in this Judicial District pursuant to Section 27 of the ExchangeAct, 15 U.S.C. §78aa and 28 U.S.C. §1391(b). Many of the acts and transactions alleged herein,including the preparation and dissemination of materially false and misleading information,

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