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-- BERNSTEIN LIEBHARD & LIFSHITZ, L
Mel E. Lifshitz (ML-2616) I 4 1 .
Michael S. Bigin (MB-0037) 1,.
IO East 40* Street
New York, NY 10016
Tel: (212) 779-1414
SCHIFFRIN & BARROWAY, LLP
Marc A. Topaz, Esq.
Three Bala Plaza East, Suite 400
Bala Cynwyd, PA 19004
Tel: (610) 667-7706
CAULEY, GELLER BOWMAN & COATES,
Paul J. Geller, Esq.
One Boca Place
2255 Glades Road - Suite 421A
Boca Raton, FL 3343 1
Tel: (561) 750-3000
Attorneys for Plaintiff
UNITED STATES DI$TRICT COURT
SOUTHERN DISTRIC$ OF NEW YORK
IN RE MERRILL LYNCH & CO., INC. ) 21 MC 96 (MP)
SECURITIES LITIGATION (ANALYST 1
RELATED CASES) 1
)
)
Tom Belcher, on Behalf of Himself and al1 Others )
Similarly Situated, ) CIVIL ACTION NO.
`1
Plaintiff, ) CLASS ACTION
) FOR VIOLATIONS
V. ) FEDERAL
`1
MERRILL LYNCH & CO., INC. and HENRY ) JURY TRIAL
BLODGET, `1
Defendants.
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Plaintiff Tom Belcher ("Plaintiff') alleges the following based upon
: counsel, which included a review of United States Securities and Exchange
SNIPPETS:
Plaintiff Tom Belcher alleges the following based upon the investigation of: counsel, which
as regulatory filings and reports, securities analysts~' reports and advisories about CMGI,
and uBid issued by MerrilI Lynch & Co. ("Merrill.
statements issued by Merrill Lynch, and media reports about CMGI, Lycos and uBid.
This is a federal securities class action brought by Plaintiff against Defendants
Merrill Lynch and Henry Blodget on bbhalf of a cIass consisting of all
stock, manipulated CMGI stock by issuing MerriIl Lynch Analyst reports regarding CMGI,
Lycos and uBid that recommended the purchase of $1 three companies' common stock and set
actions ofbuyers and sellers of Internet securities qy issuing favorable analyst reports,
analyst reports in order to obtain new and maintaid existing investment banking relationships
with Internet companies that were developed by C$IGI or in which CMGI made strategic
Lycos comprised up to 30% of CMGjI's total assets.
significantly and artificially inflated the price of C IGI securities throughout the Class
Defendant Blodget was at all releva$t times an Internet stock analyst and Vice
the Internet research analysts (the "Internet Group") at Merrill Lynch
the analysts' true opinions of the companies; no "reduce" or "sell" recommendations were
issued as a matter of undisclosed, internal policy, thereby converting a publisbed five-point
investment banking clients, thereby producing misI(eading ratings that were neither objective
s Please provide complete details on your involvement in the transaction, paying particular
a banker generally should be barred from discussing such inside infomlation with a research
investment banking and underwriting services to Internet companies and Defendants' awareness
"Our job is not to be stock pickers, but to be correct on trends, and help investors pick
Browning, "Abreast of the Market: What Moves Markets: New Forces Are Now Powering Surging
It takes a certain cachet to make financial-mbrket types swoon.
There is nothing too risky about sticking an ye-popping price target on a stock anymore
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