Several class actions have been filed against Royal Dutch Petroleum Company and The Shell Transport and Trading Company, PLC (NYSE:RD) and certain of its officers and directors by stockholders who purchased the company's common stock between December 3, 1999, and January 9, 2004. The actions claim that the defendants violated federal securities laws by issuing a series of material misrepresentations to the market over this time period, thereby artificially inflating the price of the company's securities. The stockholders seek to recover compensatory damages for the loss of value of their stock.

The action alleges that the defendants deliberately violated accounting rules and guidelines relating to oil and gas reserves that resulted in a 20% overstatement of oil and gas reserves, the eventual disclosure of damaged purchasers of the company’s securities. More specifically, Royal Dutch allegedly classified and reported in SEC filings and other documents, certain reserves as "proved reserves" from the Gorgon joint venture and various projects in Nigeria. Unknown to investors, the reserves allegedly did not meet industry and SEC requirements necessary to be classified as "proven," thereby materially inflating a key measure of the companies' financial position. On January 9, 2004, Royal Dutch announced that it was going to write-down its proved oil and gas reserves by 20% or 3.9 billion barrels. Following the announcement, Royal Dutch ADR's fell approximately 7.9% from $52.76 to $48.61.

Also named as defendants in the action are Shell Petroleum, N.V., Shell Petroleum, Ltd., Maarten van der Bergh, Judy Boynton, Malcom Brinded, S.L. Miller, Harry J.M. Roels, Paul D. Skinner, M. Moody-Stuart, Jeroen van der Veer and Philip R. Watts.

If you purchased the securities issued by Royal Dutch Petroleum, you may request appointment by the court as a lead plaintiff if you do so by March 26, 2004. A lead plaintiff is a representative party that acts on behalf of other class members in directing the litigation. In order to be appointed lead plaintiff, the court must determine that your claim is typical of the claims of other class members, and that you will adequately represent the class. Under certain circumstances, one or more class members may together serve as lead plaintiff. Your ability to share in any recovery is not affected by the decision whether or not to serve as a lead plaintiff. You may retain any counsel of your choice to serve as you in this action, or you may choose to do nothing, and remain in the class as a silent member.