According to SEC documents, The St. Paul Travelers Companies, Inc. ("St. Paul" or the Company) is one of the oldest insurance organizations in the United States, dating back to 1853. It was the result of an April 2004 merger between Travelers and St. Paul.

The original Complaint alleges that Defendants violated the federal securities laws by issuing materially false and misleading statements throughout the Class Period that had the effect of artificially inflating the market price of the Company’s securities.

The Complaint alleges that during the Class Period, Defendants made statements that were materially false and misleading because they failed to disclose and misrepresented the following adverse facts: (a) the Company had implemented and executed an unsustainable business practice whereby the Company designed and executed a business plan under which it agreed to pay so-called "contingent commissions" to insurance brokers to have them steer business to St. Paul and shield St. Paul from competition; (b) the Company’s illicit scheme exposed the Company to significant regulatory penalties and threatened loss of consumer goodwill jeopardizing the Company’s ability to sustain any performance in its legitimate business practices; (c) the Company’s revenues and earnings would have been significantly less had the Company not engaged in such unlawful practices; (d) and the Company’s prospects were at risk because its business and revenue could and would not be sustained when the public learned of its unlawful practice alleged herein.

As summarized by the Company’s FORM 10-Q for the quarterly period ended September 30, 2007, in November 2004, two purported class actions were brought by certain shareholders of the Company against the Company and certain of its current and former officers and directors. These two actions were consolidated as In re St. Paul Travelers Securities Litigation II. On July 11, 2005, an amended consolidated Complaint was filed. The amended and consolidated Complaint alleged violations of federal securities laws in connection with the Company’s alleged failure to make disclosure relating to the practice of paying brokers commissions on a contingent basis, the Company’s alleged involvement in a conspiracy to rig bids and the Company’s allegedly improper use of finite reinsurance products. On September 26, 2005, the Company and the other Defendants in In re St. Paul Travelers Securities Litigation II moved to dismiss the amended consolidated Complaint for failure to state a claim. Oral argument on the Company’s motion to dismiss was presented on June 15, 2006. By order dated September 25, 2006, the Court denied the Company’s motion to dismiss. On November 3, 2006, the Company and the other Defendants in In re St. Paul Travelers Securities Litigation II moved for partial judgment on the pleadings seeking dismissal of the allegations relating to the allegedly improper use of finite reinsurance products. On June 1, 2007, the Court granted that motion and permitted the lead Plaintiff to replead. On June 8, 2007, the lead Plaintiff filed a second amended and consolidated Complaint alleging the same claims as in the first amended and consolidated Complaint but extending the putative class period. On July 11, 2007, the Company and other Defendants in In re St. Paul Travelers Securities Litigation II moved to dismiss the second amended and consolidated Complaint. That motion remained pending. The lead Plaintiff in In re St. Paul Travelers Securities Litigation II moved for certification of a class of all purchasers of securities of the Company and St. Paul from January 27, 2000, through and including November 16, 2004. That motion was then pending.

According to a press release dated January 4, 2008, St. Paul has agreed to pay $77 million to put to rest a purported class action alleging insurance securities fraud resulting from the Company's alleged involvement in a bid-rigging scandal, the New Mexico attorney general announced. The lead Plaintiffs, which are the state of New Mexico and its retirement systems, estimated that its losses due to the alleged insurance securities fraud approached $8 million. Final reimbursement numbers will be worked out in the ongoing damage recovery process, according to the attorney general's office. Earlier this week, St. Paul made note of the agreement in a filing with the U.S. Securities and Exchange Commission, but did not disclose the amount of the settlement or any additional details. The plaintiffs in the case, dubbed In Re: St. Paul Travelers Securities Litigation II, claimed that St. Paul made false and misleading statements about their finances, which were artificially inflated by the Company's participation in a much-probed insurance industry conspiracy led by Marsh & McLennan Cos.