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 12/05/2001, the complaint alleges violations of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 promulgated thereunder. On or about October 29, 1999, Chartered commenced an initial public offering of 225,000,000 of its shares of common stock at an offering price of $20 per share (the "Chartered IPO"). In connection therewith, Chartered 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) Defendants had solicited and received excessive and undisclosed commissions from certain investors in exchange for which Defendants allocated to those investors material portions of the restricted number of Chartered shares issued in connection with the Chartered IPO; and (ii) Defendants had entered into agreements with customers whereby Defendants agreed to allocate Chartered shares to those customers in the Chartered IPO in exchange for which the customers agreed to purchase additional Chartered shares in the aftermarket at pre-determined prices.