UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
CLASS ACTION COMPLAINT
1. This is a stockholder class action brought on behalf of the public stockholders of ADC
Telecommunications Inc., (“ADC” or the “Company”) against the Company’s Board of Directors (the “Board”)
for breaches of fiduciary duty arising out of Defendants’ decision to sell the Company to Tyco Electronics, Ltd.
and its wholly-owned subsidiary Tyco Electronics Minnesota, Inc. (collectively “Tyco”) at an inadequate and for
an unfair price following a grossly unfair process (the “Proposed Merger”) pursuant to an Agreement and Plan of
Merger between ADC and Tyco dated as of July 12, 2010 (the “Merger Agreement”).
2. Plaintiffs allege that the sale of ADC to Tyco contemplated by the Merger Agreement is unfair
and inequitable to the ADC public stockholders and constitutes a breach of the fiduciary duties of the directors in
the sale of ADC. Plaintiffs also allege that the Merger
MILFORD and RONNAE D. PATSEL,
CIVIL ACTION NO.
ROBERT E. SWITZ, JOHN D. WUNSCH,
JOHN J. BOYLE, LARRY W. WANGBERG,
MICKFY P. FORET, JOHN E. REHFELD, LOIS
M. MARTIN, KRISH A. PRABHU, DAVID A.
ROBERTS, WILLIAM R. SPIVEY, TYCO
ELECTRONICS MINNESOTA, INC., TYCO
ELECTRONICS, LTD, and ADC
Class Action Complaint for Violations of the Federal
JURY TRIAL DEMANDED
Agreement and transactions approved and contemplated thereby, including the Tender Offer, are unfairly and
inequitably coercive to the public stockholders in a sale of the Company and that the stockholders are not
provided with a voluntary choice whether to tender their shares.
3. The Merger Agreement contemplates, among other things, a tender offer by