The complaint alleges that defendants violated Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 and Rule 10b-5 promulgated thereunder. More specifically, the complaint alleges that the Company failed to disclose and misrepresented the following material adverse facts which were known to defendants or recklessly disregarded by them: (1) that AIG entered into and concealed illegal contingent commission agreements that it entered into with other insurance companies, including Marsh, Inc., a subsidiary of Marsh & McLennan, Inc.; (2) that AIG engaged in bid rigging whereby the Company agreed to provide brokers with artificial quotes which were not justified by underwriting analysis; (3) that as a result of the bid rigging, AIG guaranteed itself material amounts of business; (4) that AIG failed to disclose that it had entered into "PNC-Style" partnerships with other insurance companies, which was contrary to its previous statements; and (4) that as a result of this illegal scheme, defendants, throughout the Class Period, materially overstated and artificially inflated AIG's earnings, income, and earnings per share.
On October 14, 2004, Attorney General Eliot Spitzer ("Spitzer") filed a suit against Marsh & McLennan Inc., alleging that it steered unsuspecting clients to insurers with whom it had lucrative payoff agreements, and that the firm solicited rigged bids for insurance contracts. Spitzer's complaint also named AIG as an alleged participant in steering and bid rigging. It was also revealed that two AIG executives: (1) Karen Radke, a senior vice president, and (2) Jean-Baptist Tateossian, a manager had pled guilty to charges related to the probe. This news shocked the market. Shares of AIG fell $6.99 per share, or 10.43 percent, on unusually high trading volume of more than 48 million shares traded, on October 14, 2004, to close at $60.00 per share. On the following day, October 15, 2004, shares of AIG tumbled an additional $2.15 per share or 3.58 percent, on more than 60 million in volume, to close at $57.85 per share.
Plaintiff seeks to recover damages on behalf of class members and is represented by, among others, the law firm of Stull, Stull & Brody. Stull, Stull & Brody has litigated many class actions for violations of securities laws in federal courts over the past 30 years and has obtained court approval of substantial settlements on numerous occasions. Stull, Stull & Brody maintains offices in both New York and Los Angeles.
If you acquired AIG securities between October 28, 1999 and October 13, 2004, you may, no later than December 14, 2004, request the Court appoint you as lead plaintiff.
A lead plaintiff is a representative party that acts on behalf of other class members in directing the litigation. In order to be appointed lead plaintiff, the Court must determine that the class member's claim is typical of the claims of other class members, and that the class member will adequately represent the class. Under certain circumstances, one or more class members may together serve as "lead plaintiff." Your ability to share in any recovery is not, however, affected by the decision whether or not to serve as a lead plaintiff. You may retain Stull, Stull & Brody, or other counsel of your choice, to serve as your counsel in this action.
If you wish to discuss this action or have any questions concerning this notice or your rights or interests with respect to these matters, please contact Tzivia Brody, Esq. at Stull, Stull & Brody by calling toll-free 1-800-337-4983, or by e-mail at SSBNY@aol.com, or by fax at 212/490-2022, or by writing to Stull, Stull & Brody, 6 East 45th Street, New York, NY 10017. You can also visit our website at www.ssbny.com.

