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\ ;ji'- IN THE COURT OE: CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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ANTHONY MORATTA,
Plaintiff,
-against- CLASS, ACTION COMPLAINT
INFINITY BROADCASTING
CC'RPORATION., MEL KARMAZIN,
DAVID T. MCLAUGHLIN, GEORGE H.
CCNRADES, ROBERT DOW.NS WALTER,
FARID SULEMAN, WILLIAM S.
LESVINE, ARTURO R. MORENO,
BRUCE S. GORDON, JEFFREY
SHERMAN and VIACOM INC.,
Defendants.
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Plaintiff, by his attorneys, alleges upon information and
belief, except as to paragraph 1 which plaintiff alleges upon
knowledge, as follows:
1. Plainti-Ef Anthony Moratta is a shareholder of
defendant Infinity Broadcasting Corporation ("Infinity" or the
"C0mpan.y" ) .
2. Defendant Infinity is a corporation duly organized
and existing under the laws of the state o:E Delaware, with its
principal offices located at 40 West 57th Street, New York, New
York 10019. Infinity operates radio stations and provides outdoor
advertising. The Company operates radio stations in cities across
the United States. Infinity's advertising business is conducted in
SNIPPETS:
defendant Infinity Broadcasting Corporation ("Infinity" or the
the United States, Canada, Mexico, Great Britain, Ireland and the
duly organized and existing under the laws of the State of Delaware
with its principal offices located at 1515 Broadway, New York, New
Viacom owns 100% of Infinity's Class
which represents approximately 64.3% of the equity
Infinity's Class A and Class B common stock.
Board of Directors and the Company's President and Chief Executive
Defendant Robert Downs Walter is a Director of
Defendant Bruce S. Gordon is a Director of Infinity.
Defendant Jeffrey Sherman is a.3irector of Infinity.
The individual defendants, as officers and/or
a fiduciary relationship and responsibility to plaintiff and the
other public shareholders of Infinity and owe to them the highest
ofi the other members of the Class and plaintiff has the same
Class and, therefore, preliminary and final injunctive relief on
Ir.finity and controls approximately 90.0% of the combined voting
power of Infinity shareholders.
is engaging in self-dealing and not acting in good faith
Plain.cif!f has no adequate remedy at law.
rescissory damages to the Class;
Court may seem just and proper.
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