MILBERG WEISS BERSHAD HYNES Women.com Networks Inc.
& LERACH, LLP
One Pennsylvania Plaza
New York, New York 10119-0165
(212) 594-5300
BERNSTEIN LIEBHARD & LIFSHITZ, LLP
10 East 40th Street
New York, New York 10016
(212) 779-1414
Co-Liaison Counsel for Plaintiff on
behalf of Plaintiffs' Executive Committee
listed on signature pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------------X
ABRAHAM KASSIN, on behalf : 01-CV-10866 (SAS)
of himself and all others :
similarly situated, : 21 MC 92 (SAS)
:
Plaintiff, :
: CLASS ACTION COMPLAINT
-against- : FOR VIOLATIONS OF
: FEDERAL SECURITIES LAW
:
WOMEN.COM NETWORKS, INC., MORGAN :
STANLEY DEAN WITTER & CO., :
INCORPORATED, DEUTSCHE BANC ALEX. :
BROWN INC., SALOMON SMITH BARNEY, :
INC., FLEETBOSTON ROBERTSON : JURY TRIAL DEMANDED
STEPHENS, INC., BEAR, STEARNS & :
CO., INC., DONALDSON, LUFKIN & :
JENRETTE SECURITIES CORPORATION, :
MERRILL LYNCH, PIERCE, FENNER & :
SMITH, INCORPORATED, MARLEEN :
MCDANIEL and MICHAEL PERRY, :
:
Defendants. :
-----------------------------------X
Plaintiff, by and through by his attorneys, as
and for its Class Action Complaint, alleges upon personal
SNIPPETS:
One Pennsylvania Plaza New York,
Co-Liaison Counsel for Plaintiff on behalf of Plaintiffs' Executive Committee listed on
SOUTHERN DISTRICT OF NEW YORK -----------------------------------X
INCORPORATED, DEUTSCHE BANC ALEX.
herein as "Women.com" or the "Company") with the Securities
and Exchange Commission or disseminated to Women.com's
Form 10-Q's, proxy statements, Quarterly Reports to
Shareholders, the Prospectus and Registration Statement
12 and 15 of the Securities Act of
including the preparation and dissemination
during the Class Period (including the trading
of Women.com stock based upon misleading information).
Brown Inc., Salomon Smith Barney, Inc.,
other wrongs complained of herein, the defendants, directly
Plaintiff purchased shares of Women.com as
of the Offering was 1820 Gateway Drive, Suite 100, San
Women.com described itself in its IPO
Morgan, as a lead underwriter, received
of the common stock of Women.com.
Each of the Individual Defendants was provided
press releases alleged herein to be materially false and/or
Women.com and the Offering price to the public
excessive and undisclosed commissions from
offering, according to the executives.
regarding violations of NASD rules connected with the sale
Due to the undisclosed material facts
including, inter alia, Regulation S-K.
or participation in the making of
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