UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JIMMY CHIN, on behalf of himself and all others
similarly situated,
CIVIL ACTION NO.
Plaintiff,
CLASS ACTION COMPLAINT
v. FOR VIOLATIONS OF FEDERAL
SECURITIES LAWS
DRKOOP.COM, INC.; DONALD HACKETT;
C. EVERETT KOOP; SUSAN JURY TRIAL DEMANDED
GEORGEN-SAAD; LOUIS SCALPATI; BANC
OF AMERICA SECURITIES LLC; BEAR
STEARNS, & CO., INC.; B.T. ALEX. BROWN,
INC.; FLEETBOSTON ROBERTSON
STEPHENS, INC.; GOLDMAN, SACHS & CO.;
J.P. MORGAN CHASE; and MERRILL LYNCH,
PIERCE, FENNER & SMITH,
INCORPORATED,
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 drKoop.com, Inc. ("DrKoop" or the
"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 DrKoop common stock, as defined
below, including, but not limited to, during the period from June 8, 1999 through December 6, 2000
"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
which included, inter alia, a review of relevant filings made by drKoop.com, Inc. ("DrKoop"
"Company") with the Securities and Exchange Commission, as well as, tele-conferences, press
news articles, analyst reports, and media reports concerning the Company.
"Class Period") to recover damages caused by defendants' violations of the federal securities
alleged malfeasance by major Wall Street securities firms.
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.
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
shareholders of defendants DrKoop, which documents were materially false and misleading,
Class Period (including the trading of DrKoop stock based upon misleading information).
underwriter defendants conduct substantial business in this district.
managing underwriter of the DrKoop initial public offering of 9,375,000 shares of common
The members of the Class are so numerous that joinder of all members is
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,
direct participation and agreement of DrKoop and the Individual Defendants.
violation of Regulation M, which governs market manipulation.
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