UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
TODD BERKLEY, on behalf of himself and all
others similarly situated,
CIVIL ACTION NO.
Plaintiff,
CLASS ACTION COMPLAINT
v. FOR VIOLATIONS OF FEDERAL
SECURITIES LAWS
TERRA NETWORKS, S.A.; JUAN
VILLALONGA NAVARRO; JUAN PEREA JURY TRIAL DEMANDED
SAENZ DE BURUAGA; JOSE ANTONIO
SANCHEZ GARCIA; ANTONIO DE ESTEBAN
QUINTANA; CREDIT SUISSE FIRST BOSTON
CORP.; BEAR, STEARNS & CO., INC.;
GOLDMAN, SACHS & CO.; J.P. MORGAN
CHASE; LEHMAN BROTHERS, INC.; and
SALOMON SMITH BARNEY, INC.,
Defendants.
Plaintiff, individually and on behalf of all other persons similarly situated, by
attorneys, for plaintiff's Complaint, allege upon the investigation made by and through plaintiff's
which included, inter alia, a review of relevant filings made by Terra Networks, S.A. ("Terra" or
"Company") with the Securities and Exchange Commission, as well as, tele-conferences, press
news articles, analyst reports, and media reports concerning the Company. Furthermore, this
is based upon plaintiff's personal knowledge as to plaintiff and plaintiff's own acts, and upon
and belief as to all other matters, based upon the aforementioned investigation.
NATURE OF THE ACTION
1. This is a class action on behalf of all persons, other than defendants and
parties, who purchased, converted, exchanged or otherwise acquired Terra common stock, as defined
below, including, but not limited to, during the period from November 15, 1999 through December 6,
2000 (the "Class Period") to recover damages caused by defendants' violations of the federal
law.
SNIPPETS:
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Plaintiff, individually and on behalf of all other persons similarly situated, by plaintiff's
which included, inter alia, a review of relevant filings made by Terra Networks, S.A.
"Company") with the Securities and Exchange Commission, as well as, tele-conferences, press
news articles, analyst reports, and media reports concerning the Company.
This is a class action on behalf of all persons, other than defendants and certain related
2000 (the "Class Period") to recover damages caused by defendants' violations of the federal
investment banks charged issuers of new securities excessive commissions and inflated
Second, investigators are examining, and have evidence, that major investment banks
exchange for promises by these customers that they would purchase additional shares of the
after-market, thereby inflating and maintaining the market price for the IPOs.
of the investigation is defendant investment bank Credit Suisse First Boston Corp.,
participation in the IPO market and after-market trading.
inflation in the IPO stock price, above the offering price, and create a false sense of
obtain allocations of stock on the offering - - but before the first after-market trade.
Securities Act of 1933 15 U.S.C. '' 77k, 77land 77o and Sections 10and
including the preparation and dissemination in this judicial district of the Prospectus
misleading, during the Class Period (including the trading of Terra stock based upon
the underwriter defendants conduct substantial business in this district.
managing underwriter of the Terra initial public offering of 24,929,918 shares of common
copies of the reports and press releases alleged herein to be materially false and/or
Manipulated Securities omitted and/or misrepresented material facts about the offering of
In direct contravention to Rules 101 and 102 of Regulation M of the Exchange Act,
participation and agreement of Terra and the Individual Defendants.
violation of Regulation M, which governs market manipulation.
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