AIG is a holding company that, through its subsidiaries, is engaged in a range of insurance and insurance-related activities in the United States and abroad.
The complaint alleges that during the Class Period, defendants disseminated false and misleading financial statements to the investing public. The true facts, which were known by each of the defendants but concealed from the investing public during the Class Period, were as follows:

(a) that the Company was paying illegal and concealed "contingent commissions" pursuant to illegal "contingent commission agreements;"

(b) that by concealing these "contingent commissions" and such "contingent commission agreements" the defendants violated applicable principles of fiduciary law, subjecting the Company to enormous fines and penalties totaling potentially tens, if not hundreds, of millions of dollars;

(c) that defendants had concealed the fact that AIG had engaged in illegal transactions with at least five additional insurers, contrary to defendants' claims on January 30, 2002; and

(d) that as a result, the Company's prior reported revenue and income was grossly overstated.

On October 14, 2004, New York State Attorney General Elliot Spitzer announced he had charged several of the nation's largest insurance companies and the largest broker with bid rigging and pay-offs he claimed violated fraud and competition laws. On this news, AIG shares fell $6.80 to $60.19 on unusually heavy trading volume of approximately 50 million shares.

Plaintiff seeks to recover damages on behalf of all purchasers of AIG publicly issued securities during the Class Period.