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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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CAROLIWE TEITELBAUM,
Plaintiff,
V. i
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1 Civil Action No. ; 'c _ - I
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PETER J. BARRIS, DIlVID C. WETMORE, )
GARY C. BUTLER, ROBERT J. 1
MCGOVERN, JAMES A. THOLEN, 1
CAREERBUILDER, INC., KNIGHT 1
RIDDER, INC. AND TRIBUNE COMPANY, )11
Defendants. :
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CLASS ACTION COMPLAINT
Plaintiff alleges on information and belief, except for
paragraph 1, which is alleged on knowledge, as follows:
PARTIES
1. Plaintiff! Caroline Teitelbaum is the owner of
common :stock of CareerBuilder, Inc. ("CareerBuilder" or the
"Company") , and has owned such stock at all relevant times.
2. Defendant CareerBuilder, a Delaware corporation
located at 10780 Parkridge Boulevard, Reston, Virginia, is a
leading provider of targeted online recruiting and employment
SNIPPETS:
Plaintiff alleges on information and belief,
common:stock of CareerBuilder, Inc. ("CareerBuilder" or the
and has owned such stock at all relevant times.
services for both employers and job seekers.
Defendant Knight Ridder, Inc. is
an In-te1rne.t subsidiary that offers a variety of online services.
By virtue of the Individual Defendants' positions
stockholders of the Company, and owe to plaintiff and the other
members of the class the highest obligations of due care,
action for the following reasons:
23,153,160 common shares of CareerBuilder outstanding, owned by
common to members of the Class,
Defendants have breached their fiduciary duties to plaintiff and
members of the Class by reason of the acts described herein.
appropr iate final injunctive relief with respect to the C lass as
IPO, defendant Wetmore sold 25,000 shares, and two other
balance continued to be owned by insiders and their affiliates
The Prospectus touted the Company's business
ENHANCE AND EXPAND CAREERBUILDER'S ONLINE
July 1'7, 2000, CareerBui.lder, Knight Ridder and Tribune announced
E'ursuant to the terms of the merger agreement,
The total value of the transaction is approximately $200
will be permitted to make a substantial investment in
on behalf of CareerBuilder's public shareholders to promote their
who have substantial conflicts of j.nterest with the Class.
Plaintiff and the Class have no adequate remedy at
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