Case 1:13-cv-06180-ER Document 37 Filed 11/14/14 Page 1 of 27 THE ROSEN LAW FIRM, P.A. Phillip Kim, Esq. Laurence M. Rosen, Esq. Kevin Chan, Esq. 275 Madison Avenue, 34th Floor New York, New York 10016 Telephone: (212) 686-1060 Fax: (212) 202-3827
[email protected] [email protected] [email protected] Lead Counsel for Plaintiffs and Class UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK : In re PetroChina Company Ltd. Securities : Master File No. 1:13-CV-6180 (ER) Litigation : : CLASS ACTION : : : : : JURY TRIAL DEMANDED : : This Document Relates to: ALL ACTIONS SECOND AMENDED CLASS ACTION COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS Lead Plaintiffs Jeffrey Klein and Samuel Ayoub (“Plaintiffs” or “PTR Group”), by and through their attorneys, allege the following upon information and belief, except as to those allegations concerning Plaintiffs, which are alleged upon personal knowledge. Plaintiffs’ information and belief are based upon, among other things, their counsel’s investigation, which includes without limitation: (a) review and analysis of regulatory filings made by PetroChina Company, Ltd. (“PetroChina” or the “Company”), with the United States Securities and 1 Case 1:13-cv-06180-ER Document 37 Filed 11/14/14 Page 2 of 27 Exchange Commission (“SEC”); (b) review and analysis of press releases and media reports issued by and disseminated by PetroChina; and (c) review of Chinese news media reports. NATURE OF THE ACTION AND OVERVIEW 1. This is a class action on behalf of purchasers of PetroChina securities between April 26, 2012, and December 17, 2013, inclusive (the “Class Period”), seeking to pursue remedies under the Securities Exchange Act of 1934 (the “Exchange Act”).