UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
DAVID CHENG, on behalf of himself and all others
similarly situated,
CIVIL ACTION NO.
Plaintiff,
CLASS ACTION COMPLAINT
v. FOR VIOLATIONS OF FEDERAL
SECURITIES LAWS
AKAMAI TECHNOLOGIES, INC.; GEORGE
CONRADES; PAUL SAGAN; TIMOTHY JURY TRIAL DEMANDED
WELLER; CREDIT SUISSE FIRST BOSTON
CORP.; DAIN RAUSCHER, INC.; MORGAN
STANLEY DEAN WITTER & CO.; J.P.
MORGAN CHASE; 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 Akamai Technologies, Inc.
"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 Akamai common stock, as defined
below, including, but not limited to, during the period from October 28, 1999 through December 6,
(the "Class Period") to recover damages caused by defendants' violations of the federal securities
2. In the wake of the raging bull market of the 1990's lies a series of
SNIPPETS:
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
WELLER; CREDIT SUISSE FIRST BOSTON CORP.; DAIN RAUSCHER, INC.; MORGAN STANLEY DEAN WITTER &
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 Akamai Technologies, Inc.
"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
parties, who purchased, converted, exchanged or otherwise acquired Akamai common stock, as
to recover damages caused by defendants' violations of the federal securities law.
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
thereby inflating and maintaining the market price for the IPOs.
of the investigation is defendant investment bank Credit Suisse First Boston Corp.,
Credit Suisse emerged as a leading underwriter of technology
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
reports to shareholders of defendants Akamai, which documents were materially false and
during the Class Period (including the trading of Akamai stock based upon misleading
the underwriter defendants conduct substantial business in this district.
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 Akamai and the Individual Defendants.
violation of Regulation M, which governs market manipulation.
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