UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THOMAS KARAKUNNEL and ROGER X
STEWARD, on behalf of themselves and all :
others similarly situated, :: Case No.
Plaintiffs, : CLASS ACTION COMPLAINT
vs. :: JURY TRIAL DEMANDED
REDIFF.COM INDIA LTD, AJIT :
BALAKRISHNAN, NITIN GUPTA, RAJIV :
WARRIER, RICHARD LI, GOLDMAN :
SACHS & Co., CREDIT SUISSE FIRST :
BOSTON CORP., and ROBERT FLEMING :
INC., ::
Defendants. :X
NATURE OF THE ACTION
This is a federal securities class action arising out of the June 14, 2000 initial
public offering (the "IPO" or "Offering") of Rediff.com India Ltd. ("Rediff" or the "Company")
of 4.6 million shares of Rediff American Depository Shares ("ADS"). This action is brought on
behalf of all persons who purchased Rediff ADSs pursuant or traceable to the IPO and through
March 20, 2001, inclusive.
JURISDICTION AND VENUE
1. The claims asserted herein arise under and pursuant to Sections 11,
12(a)(2) and 15 of the Securities Act of 1933, as amended (the "Securities Act") [15 U.S.C.
§§ 77k, 77l(2) and 77o].
2. This Court has jurisdiction of this action pursuant to Section 22 of the
Securities Act [15 U.S.C. § 77v] and 28 U.S.C. §§ 1331 and 1337.
3. Venue is properly laid in this District pursuant to Section 22 of the
Securities Act and 28 U.S.C. § 1391(b) and (c). The acts and conduct complained of herein,
including the preparation, issuance and dissemination of materially false and misleading
information to the investing public, occurred in substantial part in this District.
4. In connection with the acts alleged in this Complaint, defendants, directly
SNIPPETS:
public offering of Rediff.com India Ltd.
of 4.6 million shares of Rediff American Depository Shares.
The claims asserted herein arise under and pursuant to Sections 11,
12and 15 of the Securities Act of 1933, as amended [15 U.S.C.
In connection with the acts alleged in this Complaint, defendants, directly
Plaintiffs Thomas Karakunnel and Roger Steward purchased Rediff
Defendant Rediff is incorporated under the laws of India and maintains its
Corporation, and Robert Fleming Inc., (collectively, the "Underwriter Defendants")
business of investment banking, underwriting and selling securities to the public.
substantial fees.
the global Indian community.
The company has a U.S. edition of its site, with content geared to the Indian community in the
Rediff earns revenue from two primary sources: advertising and
revenue streams depend on Rediff's ability to attract viewers to its website,
"Prospectus") for the Offering.
This action alleges that defendants failed to disclose numerous facts about
qualifications of its management and directors, and significant software problems which
The Offering Was Materially False And Misleading
which point he was quoted in several publications.
[Against All Defendants For Violations Of Section 11 Of The Securities Act]
The Registration Statement, which contained the Prospectus for the Initial
Rediff is the registrant for the ADSs sold to plaintiffs and other members
Each of the Individual Defendants were directors and/or executive officers
Plaintiffs and the members of the Class acquired Rediff ADSs pursuant to,
Securities Act on behalf of all purchasers of Rediff ADSs in connection with, and traceable
investigation of the statements contained in the Offering materials,
By reason of the conduct alleged herein, these defendants violated, and/or
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