UNITED STATES
SOUTHERN DISTRI
NEIL TRAMA, on Behalf of Himself and all
Orhers Similarly Simated,
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_- CIVIL ACTION NO.
Plaintiff,
V. CLASS ACTION
FOR WOLAT
MERRILL LYNCH & CO., MC. and SECURITIES
HENRY M. BLODGET
Defendanrs.
Plaintiff, individually and on behalf of all orhers similarly situated
attorneys, for his complaint, alleges upon personal knowledge as ro himself and his own
upon information and belief as to all other matters, based upon the investigarion made
through his arromeys, which investigation included, among other things, a review of
filings by Inrerliant, Inc. ("Interliant" of the "Company") wirh rhe United States
Exchange Cornmission ("SEC"), press releases issued by Inrerlianr and Merrill Lynch &
("Merrill Lynch"), media reports about Interiianr and Merrill Lynch, the
Registration Statement dared July 7, 1999 (the "Prospecrus") for the initial offering
and other internet-related companies, and the Affidavit In Support of Application for
Pursuant to General Business Law Section 3% filed by rhe New York Stated Attorney
Offke in its investigation of Merrill Lynch's stock recommendations issued by research
NATURE OF ACTION
1. This class acrion alleges char. Merrill Lynch and its former lead
analyst, Henry M. Blodget ("Blodget"), participated in a scheme to manipulate the marker
of Inrerliant common stock, The scheme was perpetrated by defendants through the
inflarsd ratings and biased research reports for Interliant common srock. Defendanrs'
SNIPPETS:
attorneys, for his complaint, alleges upon personal knowledge as ro himself and his own acts
filings by Inrerliant, Inc. wirh rhe United States Securities and
Exchange Cornmission, press releases issued by Inrerlianr and Merrill Lynch & Co., Inc.
1999 for the initial offering of Interliant
Pursuant to General Business Law Section 3% filed by rhe New York Stated Attorney General's
Offke in its investigation of Merrill Lynch's stock recommendations issued by research
analyst, Henry M. Blodget, participated in a scheme to manipulate the marker price
inflarsd ratings and biased research reports for Interliant common srock.
with regard to Interliant common stock WAS part of a larger scheme whereby Merrill Lynch
research analysts al Men-ill Lynch published ratings for intemer: stocks that were misleading
Sections 10and 20of rhe Exchange Act and Rule lob-5
promulgated thereunder by the Securities and Exchange Commission [17 C.F.R. 9
In connection with the acrs, uansacrions and conducr alleged herein, defendants
used the means and instrumentaliries of interstate commerce, including The United States
Plaintiff purchased shares of the Company's common stock during the Class
Period as set forth in the cenification attached to this Complaint,
Plaintiff brings this action as a class action pursuant to Federal Rule of Civil
Throughour the Class Period, Interliant common shares were actively traded on
Interliant omitted and/or misrepresented material facts about Merrill Lynch's investment
Interlianr's stock price.
and underwriting business in the internet sector.
Interliant, had reported revenues of $4,9 million and an operating loss of $10,870,000, and
million, negative EBITDA of $8-2 million, and a new loss of $15.7 million.
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