According to a Press Release dated August 16, 2001, the complaint charges defendants with violations of the Securities Act of 1933 and the Securities Exchange Act of 1934 for issuing a Registration Statement and Prospectus (the "Prospectus") that contained materially false and misleading information and failed to disclose material information. The Prospectus was issued in connection with Ziff-Davis's initial public offering of 8,000,000 shares of common stock at $19.00 per share that was commenced on or about March 30, 1999. The complaint alleges that the Prospectus was false and misleading because it failed to disclose (i) Goldman Sachs' agreement with certain investors to provide them with significant amounts of restricted Ziff-Davis shares in the IPO in exchange for exorbitant and undisclosed commissions; and (ii) the agreement between Goldman Sachs and certain of its customers whereby Goldman Sachs would allocate shares in the IPO to those customers in exchange for the customers' agreement to purchase Ziff-Davis shares in the after-market at pre-determined prices.