According to a press release dated April 29, 2005, the complaint alleges that defendants, including the CEO, violated Sections 10(b) and 20(a) of the Securities Exchange Act of 1934, and Rule 10b-5 promulgated thereunder, by issuing a series of material misrepresentations during the Class Period, thereby artificially deflating the price of Tyco common stock. Specifically, the complaint alleges that defendants overstated and misrepresented material adverse facts that were known to, or recklessly disregarded, by them and: 1) conspired to encourage the initiation of criminal actions against Dennis Kozlowski, Mark H. Swartz, and Mark A. Belnick in an effort to protect the former members of the Board of Directors from liability; 2) employed a strategy that included, in part, leaking information to the media in an effort to artificially deflate share prices for the benefit of new management; and 3) recklessly disregarded the likelihood of significant dilution of Tyco equity resulting from inefficiencies and additional expenses in implementing this strategy.

If you bought Tyco International Ltd. securities between June 15, 2002 and December 31, 2004, inclusive, and would like to obtain information about the lawsuit, then you are invited to call (866) 467-1400 to speak with an attorney.