Other actions have been filed making similar allegations regarding the IPOs of more than 300 other companies. All of these have been coordinated for pretrial purposes as In re Initial Public Offering Securities Litigation, Civil Action No. 21-MC-92.

Specifically, the complaint alleges violations of Sections 11, 12(a)(2) and 15 of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 promulgated thereunder. On or about October 19, 1999, Radio Unica commenced an initial public offering of 6.84 million of its shares of common stock at an offering price of $16 per share (the "IPO"). In connection therewith, Radio Unica filed a registration statement, which incorporated a prospectus (the "Prospectus"), with the SEC. The complaint further alleges that the Prospectus was materially false and misleading because it failed to disclose, among other things, that: (i) the Underwriters had solicited and received excessive and undisclosed commissions from certain investors in exchange for which those Underwriters allocated to those investors material portions of the restricted number of IPO shares issued in connection with the Radio Unica IPO; and (ii) the Underwriters had entered into agreements with customers whereby the Underwriters agreed to allocate shares to those customers in the Radio Unica IPO in exchange for which the customers agreed to purchase additional Radio Unica shares in the aftermarket at pre-determined prices.