Also named in the action are Hollinger, Inc., Ravelston Corporation, Ltd., Ravelston Management, Inc., KPMG, LLP, Argus Corporation, Ltd., Conrad N. Black, Dwayne O. Andreas, Peter Y. Atkinson, Barbara A. Black, Jack A. Boultbee, Richard R. Burt, Richard G. Chambers, Daniel W. Colson, Mark S. Kipnis, Henry A. Kissinger, Marie Josee Kravis, Shmuel Meitar, Richard N. Perle, F. David Radler, Robert S. Strauss, A. Alfred Taubman, James R. Thompson, Lord Weidenfeld, and Leslie H. Wexner

The action alleges that, during the applicable period, the defendants: (1) misrepresented the terms of Hollinger's asset sales by failing to disclose that significant portions of the proceeds from the asset sales were diverted to defendants Hollinger Inc., Lord Black, Radler, Boultbee and Atkinson under the guise of purported 'non-compete' payments; (2) misrepresented the terms of management services agreements between Hollinger and its parent corporation (controlled by Lord Black) Hollinger, Inc. and entities controlled by Lord Black and certain of the defendants, and concealed the fact that Hollinger was paying purported management services fees to those entities without having them provide any services to Hollinger; (3) misrepresented the terms of Hollinger's asset sales to entities owned and controlled by Lord Black and other defendants in transactions at below market prices, where in some cases Hollinger sold newspapers for one dollar which others had offered to buy for over $1 million; and (4) misrepresented Lord Black's compensation, by failing to disclose millions of dollars paid to Lord Black by a Hollinger subsidiary. The defendants allegedly compounded their fraud by falsely claiming that Hollinger's asset sales, the non-compete payments to Lord Black and other defendants, and other related-party transactions, were approved by Hollinger's Board of Directors and the Audit Committee of the Board of Directors, when they were not. As a result of defendants' materially false and misleading statements during the period, the investing public was deceived, the market price of Hollinger's stock was artificially inflated, and plaintiff and other members of the class were damaged by their purchases of Hollinger stock at prices artificially inflated by defendants' fraud.

Once Hollinger finally disclosed to its shareholders some of the information about the self-dealing transactions and non-compete payments in the company's SEC filings, it allegedly misrepresented the amount of the non-compete payments, it falsely stated that those payments were 'required' to close the company's assets sales, and it falsely claimed that the company's independent directors had approved the payments. Hollinger's SEC filings also allegedly failed to disclose that, although the company was paying Ravelston Corporation millions of dollars each year pursuant to management services agreements, Ravelston was not providing any services to the company. Hollinger's SEC filings also failed to disclose the terms of its prior asset sales which were designed to favor companies controlled by Lord Conrad Black and other defendants.

Hollinger's misrepresentations and fraud allegedly began at least as early as the filing of its Form 10-Q with the SEC on August 13, 1999, at which time Hollinger's stock traded at $10.08 per share, but as a result of defendants' misrepresentations and fraud, Hollinger's stock was artificially inflated and traded at $13.11 per share by March 28, 2002. As the marketplace reacted to the news of Lord Black's self-dealing, Hollinger's stock began to drop in price, but it was not until March 31, 2003, under pressure from its institutional investors, that Hollinger disclosed the improprieties by Lord Black and the other defendants, and the price of the company stock dropped that day to $7.90 per share.