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.

According to a Press Release dated November 16, 2001, 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 May 5, 1999, Radio One commenced an initial public offering of 6,500,000 of its shares of common stock at an offering price of $24 per share (the "Initial Offering") and on November 12, 1999, Radio One commenced a secondary public offering of 5,400,000 of Radio One shares of common stock at an offering price of $59.25 per share (the "Secondary Offering"). Radio One filed registration statements with the SEC in connection with the Initial Offering and the Secondary Offering, each of which incorporated a prospectus (the "Prospectuses"). The complaint further alleges that the Prospectuses were materially false and misleading because each failed to disclose, among other things, that: (i) the Underwriter Defendants had solicited and received excessive and undisclosed commissions from certain investors in exchange for which the Underwriter Defendants allocated to those investors material portions of the restricted number of Radio One shares issued in connection with the Initial Offering and the Secondary Offering; and (ii) the Underwriter Defendants had entered into agreements with customers whereby they agreed to allocate Radio One shares to those customers in the Initial Offering and Secondary Offering in exchange for which the customers agreed to purchase additional Radio One shares in the aftermarket at pre-determined prices.