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1
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COMPLAINT
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EXTRACTED KEY WORDS
AOL TIME WARNER SECURITIES PLAINTIFF DEFENDANTS OFFICER ADVERTISING EXCHANGE REVENUES TRADED SECURITIES REPORTS AMERICA ONLINE VIOLATION ASSETS MERGER DIRECTORS MISLEADING COMMON STOCK INDIVIDUAL DEFENDANTS MATERIALLY FALSE EXCHANGE ACT OFFERING CUSTOMERS FREE CASH FLOWS UNITED STATES SECURITIES PURCHASERS MATERIAL ADVERSE EXECUTIVE OFFICER AOL EUROPE MANAGEMENT ACCOUNTING |
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
DELBERT CURRENS, on Behalf of Himself and all )
Others Similarly Situated, ) CASE NO.
>
Plaintiff, >
) CLASS ACTION COMPLAINT
vs. ) FOR VIOLATIONS OF
) FEDERAL SECURITIES LAWS
AOL TIME WARNER l-NC., STEPHEN CASE, )
MICHAEL KELLY, RICHARD PARSONS and )
GERALD M. LEVIN, ) JURY TRIAL DEMANDED
Defendants. i
Plaintiff has alleged the following based upon the investigation of pIaintiff s
which included a review of United States Securities and Exchange Commission ("SEC')
by AOL Time Warner Inc. ("AOL Time Warner" or the "Company"), as well as regulatory
and reports, securities a.nalysts' reports and advisories about the Company, press releases
other public statements issued by the Company, and media reports about tbe Company, and
plaintifT believes &at substantial additional evidentiary support will exist for the
foti herein asker a reasonable opportunity for discovery.
SUMMARY AND OVERVIEW
1. This is a securities fraud class action on behalf of all purchasers of the
traded securities of AOL Time Warner between April 18, ZOO 1 and April 24, 2002 (the
Period"), against .AOL Time Warner and certain of its officers and directors for
Sectities Exchange Act of 1934 (the "Exchange Act"). .r;.uL Time Warner Is a media and
communications company.
2. The Company was formed on January 11,200 1, when America Online and Time
Warner consummated their merger, which had been pending completion since its announcement
in January 2000. The merger was structured as a purchase of Time Warner by America Online.
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