MARK S. THOMSON, on Behalf of Himself: No
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ___________________________________ MARK S. THOMSON, on behalf of himself: No. ___________________ and all others similarly situated, : : CLASS ACTION COMPLAINT Plaintiff, : FOR VIOLATIONS OF THE : FEDERAL SECURITIES LAWS v. : : MORGAN STANLEY DEAN WITTER : & CO. and MARY MEEKER, : : Defendants. : JURY TRIAL DEMANDED ___________________________________ : Plaintiff, by his undersigned attorneys, individually and on behalf of the Class described below, upon actual knowledge with respect to the allegations related to plaintiff’s purchase of the common stock of Amazon.com, Inc. (“Amazon” or the “Company”), and upon information and belief with respect to the remaining allegations, based upon, inter alia, the investigation of plaintiff’s counsel, which included, among other things, a review of public statements made by defendants and their employees, Securities and Exchange Commission (“SEC”) filings, and press releases and media reports, brings this Complaint (the “Complaint”) against defendants named herein, and alleges as follows: SUMMARY OF THE ACTION 1. In October 1999, Fortune named defendant Mary Meeker (“Meeker) the third most powerful woman in business, commenting, “[h]er brave bets – AOL in ‘93, Netscape in ‘95, e-commerce in ‘97, business to business in ‘99 – have earned her eight “ten-baggers”, stocks that have risen tenfold. Morgan Stanley’s “We’ve got Mary” pitch to clients has been key to its prominence in Internet financing. Her power is awesome: If she ever says “Hold Amazon.com”, Internet investors will lose billions.” 2. Fortune almost got it right. Investors did lose billions, but not because Meeker said “Hold Amazon.com”. Rather, investors were damaged by Meeker’s false and misleading statements encouraging investors to continue buying shares of Amazon.
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