UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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COLLEGEWARE USA, INC., on behalf :
of itself and all others : 01-CV-4186 (JSM)
similarly situated, :
:
Plaintiff, : CLASS ACTION COMPLAINT
:
-against- : JURY TRIAL DEMANDED
:
STAMPS.COM INC., JOHN M. PAYNE, :
JOHN W. LAVALLE, THOMAS H. :
BRUGGERE, MOHAN P. ANANDA, DAVID :
C. BOHNETT, JEFFREY J. BROWN, :
THOMAS N. CLANCY, G. BRADFORD :
JONES, MARVIN RUNYON, LOREN E. :
SMITH, CAROLYN M. TICKNOR, :
BANCBOSTON ROBERTSON STEPHENS, :
INC., THE GOLDMAN SACHS GROUP, :
INC., SALOMON SMITH BARNEY, INC. :
and CREDIT SUISSE FIRST BOSTON :
CORPORATION,
:
:
Defendants. :
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Plaintiff, by and through by its attorneys, as
and for its Class Action Complaint, alleges upon personal
knowledge as to its own acts and as to all other matters
upon information and belief based upon, inter alia, the
investigation made by and through its attorneys, which
investigation included, among other things, a review of
reports filed by Stamps.com Inc. ("Stamps.com" or "the
SNIPPETS:
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Plaintiff,: CLASS ACTION COMPLAINT
INC., SALOMON SMITH BARNEY, INC.:
disseminated to Stamps.com's shareholders (including
Prospectus and Registration Statement dated June 24, 1999,
(the "IPO Prospectus"), the Prospectus and Registration
Statement dated December 6, 1999 (the "Secondary Offering
trading volume of Stamps.com's securities and interviews as
12 and 15 of the Securities Act of
77o and Sections 10and 20of the Exchange Act 15
including the preparation and dissemination
Class Period (including the trading of Stamps.com stock
based upon misleading information).
underwriters The Goldman Sachs Group, Inc., Salomon Smith
other wrongs complained of herein, the defendants, directly
Plaintiff purchased shares of Stamps.com
percent, of Stamps.com's common stock.
Defendant BancBoston Robertson Stephens,
was a lead underwriter of the Stamps.com initial public
Defendant Credit Suisse First Boston
"Individual Defendants" (except that defendant Ticknor is
press releases alleged herein to be materially false and/or
Offering omitted and/or misrepresented material facts about
Stamps.com and the IPO price to the public ($11.00
and the underwriting discounts and commissions,
STATEMENTS AND VIOLATIONS OF SEC
Regulation S-K, Item 501required
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