Salomon Smith Barney, Inc. ("Salomon" or the Company) is an investment bank.

The Complaint alleges that Salomon and its well-known telecommunications stock analyst Jack Grubman violated the federal securities laws by knowingly issuing false and misleading analyst reports regarding WorldCom during the Class Period. The Complaint alleges that Salomon failed to disclose a significant conflict of interest between their investment banking and research departments. Specifically, Jack Grubman and other Salomon analysts issued very favorable analyst reports regarding WorldCom to the public when they allegedly knew that the positive recommendations were unwarranted. Unbeknownst to the investing public, Salomon's buy recommendations and price targets for WorldCom were influenced by its efforts to be retained as a financial advisor for WorldCom and other telecommunications companies. Such lucrative investment banking engagements were worth millions of dollars in fees to Salomon.

On January 28, 2003, this Court consolidated approximately 80 actions involving allegations of securities fraud in connection with analyst research reports, into nine lead actions organized by issuer. This case was consolidated into the case filed under Docket 02-CV-07966.