IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
(Alexandria Division) I "--"I \\
rcI'-..'
RAYMOND TYLER, on Behalf of Himself and )
All Others Similarly Situated,
Plaintiff,
)
VS. ) Case No. 2 - kwq-A
)
CAPITAL ONE FINANCIAL CORP.,
Serve: Any Officer, Director or Managing Agent
2980 Fairview Park Drive, Suite 1300
Falls Church, VA 22042
and
RICHARD D. FAIRBANK,
2980 Fair-view Park Drive, Suite 1300
Falls Church, VA 22042
and
/
NIGEL W. MORRIS, and ) Class Action Lawsuit for
2980 Fair-view Park Drive, Suite 1300 ) Violations, with Jury
Falls Church, VA 22042 1
)
and 1
)
DAVID M. WILLEY, 1
2980 Fair-view Park Drive, Suite 1300 1
Falls Church, VA 22042 )
1
Defendants. 1
COMPLAINT
Plaintiff has alleged the following based upon the investigation of
counsel, which included a review of United States Securities and Exchange Commission
filings by Capital One Financial Corp. ("Capital One" or the "Company"), as well as
filings and reports, securities analysts reports and advisories about the Company, press
SNIPPETS:
Any Officer, Director or Managing Agent
Plaintiff has alleged the following based upon the investigation of plaintiffs
filings and reports, securities analysts reports and advisories about the Company, press
to pursue remedies under the Securities Exchange Act of 1934.
In connection with the acts alleged in this complaint, defendants, directly
dissemination of materially false and misleading information, occurred in substantial part in
principal place of business within the Eastern Uistrict of Virginia.
Defendant Richard D. Fairbank was Capital One's Chief
The Individual Defendants also had access to material adverse nonpublic information
about its business, finances, products, markets and present and future business prospects via
The members of the Class are so numerous that joinder of all members is
shares of common stock outstanding, which were actively traded on the New York Stock
The Company operates throughout the United States and also conducts business internationally,
One Bank and Capital One,
The Bank, a credit card bank, is organized as a limited-purpose banking
The Savings Bank is a federal savings bank chartered by the Office of
loan loss reserve and capital adequacy requirements for the Bank and Savings Bank,
Compliance with these guidelines is crucial for the Company, as the Federal Reserve and OTS
These statements were materially false and misleading because Capital
sell over $8.2 million worth of the Company's common stock at artificially inflated prices.
marked the Company's 20th consecutive quarter of record earnings,
Bank regulatory authorities have recently completed a routine
for loan losses and other regulatory requirements.
Exchange Commission and available on the company's web&c.
its infrastructure including crucial information systems and risk management capabilities,
loan losses is adequate to cover anticipated losses in the reported homogeneous consumer loan
and efficient at all relevant times.
misleading statements and omitting to disclose material facts necessary to make defendants'
purchasers of Capital One's securities during the Class Period suffered similar injury through
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