The defendants consist of the companies that made public offerings, certain of their officers and directors, and 55 of the investment banks that brought them public and underwrote various follow-on offerings. Lists of the defendants may be found at www.ipofraud.com. The lawsuits allege that the IPOs were manipulated by the investment banks to artificially inflate the market price of those securities and to conceal the amounts of compensation actually received by the underwriters.

The settlement guarantees at least $1 billion to class member investors which will come from the issuers’ insurers. This amount is separate from any recoveries to be received by investors as a result of any government or regulatory action. The cases against the 55 investment bank underwriter defendants are not settled by this agreement, but continue in litigation.

A memorandum of understanding to settle the plaintiffs' claims against the issuers and their directors and officers has now been approved as to form by counsel, and the process of obtaining approval by all parties is now underway. The parties will be required to prepare many complex documents necessary to consummate the settlement, which will be submitted to the Court for preliminary approval. Final approval will be required by the court following notice to class members and a fairness hearing. No dates for these hearings have been set as of May 9, 2004.