According to a Press Release dated August 16, 2001 the complaint alleges that the Internet Infrastructure Depositary Receipts were ``basket securities'' whose price was directly related to, and moved with, the price of 20 underlying securities held in the Internet Infrastructure Holdrs trust. The complaint further alleges that defendants violated the federal securities laws by issuing and selling Internet Infrastructure Holdrs Depositary Receipts in an IPO on February 24, 2000, pursuant to a registration statement and prospectus that were materially false and misleading because they failed to disclose that a substantial proportion of the Internet Infrastructure Holdrs trust's initial portfolio consisted of stocks whose prices had been artificially inflated through the use of improper practices relating to their initial public offering, and that they therefore traded at artificially inflated prices.