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 24, 2003, this Court consolidated approximately 80 actions against Salomon and Jack Grubman, et al., involving allegations of securities fraud in connection with analyst research reports, into nine lead actions organized by issuer. The cases were pending before the Hon. Gerard E. Lynch, U.S. District Judge, S.D.N.Y.

In a press release dated August 12, 2004, Citigroup -- one of a number of Defendants -- agreed to create a $2.65 billion settlement fund in May, without admitting any wrongdoing. Claims against the New York bank related to both underwriting of WorldCom bonds and to alleged fraud in connection with secondary market trading of stocks and bonds, most notably in connection with former telecommunications analyst Jack Grubman, who touted WorldCom shares.

According to the docket, on August 20, 2004, the Court issued a Stipulation and Order granting the proposed transfer of the In Re Salomon Analyst Worldcom Litigation. The proposed dismissal of the claims in In Re Salomon Analyst WorldCom with prejudice and without costs or expenses to any party was granted but conditioned such that the dismissal of claims only become effective upon final approval of the settlement between the parties in the WorldCom Securities Litigation. The case was accepted as related to 1:02-cv-3288 and reassigned to Judge Denise L. Cote.