UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ANTHONY CARRUBBA, on behalf of himself
and all others similarly situated,
CIVIL ACTION NO.
Plaintiff,
CLASS ACTION COMPLAINT
v. FOR VIOLATIONS OF FEDERAL
SECURITIES LAWS
ROWECOM, INC.; RICHARD ROWE;
LOUIS HERNANDEZ, JR.; CIBC WORLD JURY TRIAL DEMANDED
MARKETS CORP.; DEUTSCHE BANK
ALEX. BROWN, INC.; FLEETBOSTON
ROBERTSON STEPHENS, INC.; J.P.
MORGAN CHASE; PRUDENTIAL
SECURITIES INCORPORATED and
SALOMON SMITH BARNEY, INC.,
Defendants.
Plaintiff, individually and on behalf of all other persons similarly situated, by
undersigned attorneys, for plaintiff's Complaint, allege upon the investigation made by and
plaintiff's counsel, which included, inter alia, a review of relevant filings made by
("RoweCom" or the "Company") with the Securities and Exchange Commission, as well as, tele-
conferences, press releases, news articles, analyst reports, and media reports concerning
Company. Furthermore, this complaint is based upon plaintiff's personal knowledge as to plaintiff
and plaintiff's own acts, and upon information and belief as to all other matters, based upon
aforementioned investigation.
NATURE OF THE ACTION
1. This is a class action on behalf of all persons, other than defendants
related parties, who purchased, converted, exchanged or otherwise acquired RoweCom common
stock, as defined below, including, but not limited to, during the period from March 9, 1999 through
December 6, 2000 (the "Class Period") to recover damages caused by defendants' violations of the
federal securities 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
plaintiff's counsel, which included, inter alia, a review of relevant filings made by
with the Securities and Exchange Commission, as well as, teleconferences, press releases,
This is a class action on behalf of all persons, other than defendants and certain
2000 (the "Class Period") to recover damages caused by defendants' violations of the
alleged malfeasance by major Wall Street securities firms.
York and enforcement officials at the Securities and Exchange Commission are examining
banks allocated shares of especially hot initial public offerings to favored,
customers in exchange for promises by these customers that they would purchase additional
of the IPOs in the after-market, thereby inflating and maintaining the market price for the
major investment banks including the Underwriter
Commissions for Hot IPOs" by staff reporters Randall Smith and Susan Pulliman.
participants in the IPO boom include Morgan Stanley Dean Witter and Goldman Sachs Groups,
kickbacks of trading profits and commitments to purchase additional shares of IPOs in the
would ensure artificial inflation in the IPO stock price, above the offering price, and
profits for investors able to obtain allocations of stock on the offering - - but before the
Securities Act of 1933 15 U.S.C. §§ 77k, 77land 77o and Sections 10
false and misleading, during the Class Period (including the trading of RoweCom stock based
the underwriter defendants conduct substantial business in this
RoweCom initial public offering of 3,100,000 shares of common stock at $16 per share pursuant
a Prospectus and Registration Statement dated March 9,
unlimited access to copies of the reports and press releases alleged herein to be materially
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,
with direct participation and agreement of RoweCom and the Individual
employed manipulation and/or deceptive devices
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