MILBERG WEISS BERSHAD HYNES AsiaInfo Holdings, 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
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BENEDETTO HASSAN, on behalf : 01-CV-10901 (SAS)
of himself and all others :
similarly situated, : 21 MC 92 (SAS)
:
Plaintiff, :
: CLASS ACTION COMPLAINT
-against- : FOR VIOLATIONS OF
: FEDERAL SECURITIES LAW
:
ASIAINFO HOLDINGS, INC., MORGAN :
STANLEY DEAN WITTER & CO., INC., :
DEUTSCHE BANC ALEX. BROWN INC., : JURY TRIAL DEMANDED
DONALDSON, LUFKIN & JENRETTE :
SECURITIES CORPORATION, LOUIS LAU, :
JAMES DING and YING HAN, :
:
Defendants. :
-----------------------------------X
Plaintiff, by and through by his attorneys, as
and for his Class Action Complaint, alleges upon personal
knowledge as to his own acts and as to all other matters
upon information and belief based upon, inter alia, the
investigation made by and through his attorneys, which
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
herein as "AsiaInfo" or the "Company") with the Securities
and Exchange Commission or disseminated to AsiaInfo'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 AsiaInfo
stock based upon misleading information).
other wrongs complained of herein, the defendants, directly
Plaintiff purchased shares of AsiaInfo as
AsiaInfo described itself in its IPO
initial public offering of 5,000,000 shares of common stock
of the common stock of AsiaInfo.
Company's initial public offering.
Each of the Individual Defendants was provided
press releases alleged herein to be materially false and/or
AsiaInfo and the Offering price to the public
excessive and undisclosed commissions from
customers agreed to and did pay the Underwriter Defendants
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.
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