For 2001 Qwest senior management established revenue and EBITDA targets for Dex that were higher than what Dex management believed was possible to achieve. In fact, the EBITDA target was allegedly $80-100 million greater than the amount Dex management believed was achievable. The SEC found that Dex management complained to Qwest’s senior management about the unrealistic targets. Yet Qwest’s senior management not only allegedly refused to change the targets but also did not allow Dex a reduction in the targets to compensate for the revenue from the Colorado Springs directory that was recognized in 2000.