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AND - SEC.gov | HOME

Richard Hong (Trial Counsel) (RH -4939) Scott W. Friestad David Frohlich Melissa A. Robertson Jeffiey B. Finnell Thomas D. Manganello Richard E. Simpson (RS -5859) Attorneys for Plaintiff Securities and Exchange Commission 100 F Street, Washington, DC 20549 Tel: (202) 55 1-443 1 (Hong) Fax: (202) 772-9246 (Hong) E-mail: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SECURITIES AND EXCHANGE COMMISSION, : Plaintiff, : 08 Civ. 0 : COMPLAINT JOHN MICHAEL KELLY, STEVEN E. RINDNER, JOSEPH A. RIPP, and MARK WOVSANIKER, : Jury Trial Demanded Defendants. Plaintiff Securities and Exchange Commission (the "Commission") alleges as follows: * NATURE OF THE ACTION 1. This is a financial fraud case against four former senior managers of America Online, Inc. ("AOL") and its successor corporation, AOL Time Warner Inc.

accounted for the round-trip transactions in order to improperly inflate AOL's online advertising revenues. 4. By their actions, knowingly or recklessly undertaken, Kelly, Rindner, Ripp, and Wovsaniker were responsible for false statements regarding the Company's revenue,

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