UNlITED STA
SOLrl'HERN L)W%`RICT"OF NEW Y,ORK
Plai&if~s have alleged kc following based upon Lht: investigation
and qotis, securities analysts' rcposrs astJ advisories about the Company, press roleuscs anki
other public sfatenxmrs issued by the C;`ompany; and m;edia reports about the Cnmpan3;: and
forth hercin ~ter a rewmahle opportunity for di~avery.
1. This: ie a ferkrnl class actiuil on behalf cf purchastis of the
Ornnico~r~ tchvccn April 25,ZOOO and June 11,20X, inclusive (she "tY%x~ Pcrioc!");
pumc remedies under the SccWies Exchange Act of 1934 (the "Excharlgt Act").
,
.,s. .
J-G-R.mICTION AND VENUE
3
a... The cI&ns asserted herein arise under and pursuant to Sections 10(b) and
the Exchange Act [15 U.S.C. @ 7'8j@) and 78t(a)] and Rule lob-5 promulgated thereunder I
the Securities and Exchange Commission ("SEC") 117 C.F.R. 5 24-O.
lob-51.
3. This Court has jurisdiction over the subject matter of this action
U-SC. $3 1331 and 1337 and SectionZ7,ofthe Exchange Act [15 U.S.C. $78aa].
SNIPPETS:
other public sfatenxmrs issued by the C;`ompany; and m;edia reports about the Cnmpan3;:
pumc remedies under the SccWies Exchange Act of 1934.
the Securities and Exchange Commission 117 C.F.R. 5 24-O.
limited to, the mails, interstate telephone communications and the facilities of the national
purchased the common stock of Omnicom at artificially
inflated prices during the Class Period and has beien damaged thereby.
business located at 437 Madison Avenue, New York, NY 10022.
Defendants Wren, WeisenburBer, Crawford and Angelash are collectiv
connections wirh other corporate officers and employees, attendance at management and Bc
It is appropriate to treat the Individual Defendants as a group for pleading
reviewing and/or disseminating the false and misleading statements and information alleget
disseminating materially false and misleading statements and/or concealing material adverse
other members of the Class to purchase Chnnicorn securities at artificially inflated prices.
Plaintiffs bring this action as a class action pursuant to FederaI Ruie of Civil
fendants, the officers and directors of the Company, at all relevant times, members of their i
Onmicom's growth was attributed, for the most part, to the numerous acquisitions made by
investments to $eneca, which had been jointly created with Pegasus Capital LLP in May 200
Seneca had bezn created as a vehicle for the Company to avoid repc
quarter of 2000, the period ending March 3 1,200O.
million in the third quarter of 1999, The Company also reported that worldwide revenue
The Company reported that net income for the fouflh quarter of 2000 increased 19% to $14:
Wren, Weisenburger, Crav&ord and Angel&o, among others, conKrmed the previouslyannounced
relying upon the integrity of the market price of Omnicom's secti tics and market inforrnati
the material misrepresentations and omissions particuh
in the issuance or dissemination of such statements or documents as primary violations of th
positions, and their ownership and contractual rights, participation in and/or awareness of
|
