M&k lbfshitz, (ML-2616)
Joseph R. Seidman (JS-9260)
10 East 40' Street
New York, New York 100 16
Telephone: (212) 779-1414
SCHWFRIN & BARRO'CVAY, UP
Marc A. Topaz, Esq.
Three Bala Plaza East, Suite 400
Bala Cymyd, PA 19004
Tel: (610) 667-7706
CAULEY, GELEER BOWNLdLN dk COATES, ELP
Paul J. GeIIer? Esq.
Attmeys for PI&tiff
James Blevins, by his attorneys, for his co&plaint defmldants Merrill
against
Co., Inc. ("Merrill Lynch"), Morgan Stanley Dean !Witter & Co,, Inc. ("Morgan Stanley"),
Blodget, and Mary Meeker, alleges as Wlows:
NATURE OF THE ACTICJN
1. This is a securities fraud class a&on on behalf of all
purchased the cormnon stock of Ii&ton-xi Corporation ("momi" or
June 10, 1998 and April 3,2001, inclusive (the `Uass" and the "Class Period," respectively).
Defendants defrauded the Class by: (i) issuing positive recommendations about Inktomi even
though there wxe no rational economic reasons or factual bases to justify such
recommendations; (ii) failing to disclose that they were issuing favorable recommendations to
SNIPPETS:
New York, New York 100 16 Telephone:
Co., Inc., Morgan Stanley Dean!Witter & Co,, Inc., Henry
June 10, 1998 and April 3,2001, inclusive (the `Uass" and the "Class Period," respectively).
Defendants defrauded the Class by: issuing positive recommendations about Inktomi even
failing to disclose that they were issuing favorable recommendations to
obt.ain investment banking business; and co@ceaIing significant,
InktonG common stock traded as high as $23 1 per share.
York and an Internet stock analyst and First Vice President of Mefill Lmch.
2001 3 Blodget resigned as an lntemet analyst $t Merrill Lynch.
Plaintiff brings this action as a glass action pursuant to Federal Rule of Civil
The Class is so numerous that joinder of all Class members is impra-cticabIe.
Inktomi's shares were publiclyltraded in an efficient,
market which assimilated the information abc$t the Company.
Class, has retained counsel competent and experienced in Class action and securities
individua1 Class members prosecuting separatei claims is remote because the damages suflered
recommendations to obtain investment banking $tlsiness;
false and misleading statements or omissions;
Inktomi was one of a number of stocks "cove1-ed" or fobllowed by Merrill Lynch
stock analysts worked in the researoh department of a brokerage fin
All of the major investment ba$ks, including defadants, began using their highprofile
single "Reduce" or "Sell" rating for any stock covered by its internet group aYld Morgan
I All stock prices noted herein have been adjusted to reflect Tao 2-for-l splits of the
On or about November 20,19/98, Lnktomi engaged in a secondary offering of its
placing- a "Near-Term Accumulare/Long-Term Buy" recommendation on the
Accumulate" rating.
dollars in losses relating to purchases of Inktomi stock.
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