Facebook's brief provides clues about how it might defend itself against the charges that it violated securities laws. The company said it is "customary" for underwriting firms to develop "forward-looking guidance" in close conversation with the companies they represent.

The lawsuits ignore that "what Facebook and the Underwriter Defendants allegedly did both followed customary practices and did not violate any rules," the brief states. The theory that it was "improper for analysts to discuss their forecasts with 'preferred' investors" is "unprecedented," Facebook's lawyers argued.

With respect to the Nasdaq's technical problems, Facebook doesn't dispute that they may have caused its stock price to sink on the opening day of trading. It notes that press reports at the time suggested the problems spurred "a cascade of selling" that made it appear as if investors were "turning against Facebook" and caused some hedge funds to "sell their entire positions because of the confusion."

Facebook filed its motion with the United States Judicial Panel on Multidistrict Litigation in Washington, D.C.

The IDG News Service