Please complete this form and list your purchase and sale transaction(s) for Deutsche Bank AG (NYSE: DB) between April 15, 2013 and April 29, 2016, inclusive (the “Class Period”):
Notice is hereby given that a class action lawsuit has been filed on behalf of those who purchased or otherwise acquired shares of Deutsche Bank AG (NYSE: DB) (“Deutsche Bank” or the Company) between April 15, 2013 and April 29, 2016, inclusive (the “Class Period”).
According to the complaint, Deutsche Bank provides investment, financial, and related products and services worldwide.
The complaint alleges that defendants issued false and misleading statements throughout the Class Period to investors and/or failed to disclose that: (1) Deutsche Bank has serious and systemic failings in its controls against financing terrorism, money laundering, aiding against international sanctions, and committing financial crimes; (2) Deutsche Bank’s internal control over financial reporting and its disclosure controls and procedures were not effective; and (3) as a result of the foregoing, defendants’ statements about Deutsche Bank’s business, operations, and prospects, were false and misleading and/or lacked a reasonable basis.
The class period begins on April 15, 2013, when the Company filed a Form 20-F for the fiscal year ended December 31, 2012 (the “2012 20-F”) with the SEC, which provided the Company’s year-end financial results and position and stated that the Company’s internal control over financial reporting and disclosure controls and procedures were effective as of December 31, 2012.
On April 14, 2016, Bloomberg published an article entitled “Deutsche Bank Found ‘Systemic’ Failure in Russia Cash Flight”, stating that the Company found a “systemic” failure in its internal controls that were designed to prevent money laundering and financial crime, and which allowed a “suspected money-laundering pattern” to pump as much as $10 billion out of Russia from 2012 through 2014.
On April 28, 2016 during aftermarket hours, Bloomberg published an article entitled “Deutsche Bank’s Thoma to Step Down in Wake of Board Clash”, stating that that Georg Thoma, Chairman of the Supervisory Board of Integrity Committee, who was brought on the Board to help improve controls and work through the Company’s various cases of misconduct, resigned as Chairman of the Committee effective immediately
Following this news, shares of Deutsche Bank fell $0.50 per share or approximately 3% from its previous closing price to close at $18.96 per share on April 29, 2016, damaging investors.
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. Your ability to share in any recovery is not, however, affected by the decision whether or not to serve as a lead plaintiff. Any member of the purported class may move the court to serve as a lead plaintiff through counsel of their choice, or may choose to do nothing and remain an inactive class member.
Kessler Topaz Meltzer & Check, LLP has not filed a complaint in this matter. 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 Kessler Topaz Meltzer & Check, LLP toll free at 1-888-299-7706 or 1-610-667-7706, or via e-mail at email@example.com. For more information about Kessler Topaz Meltzer & Check, LLP, please visit our website at http://www.ktmc.com. If you would like additional information about the suit, please fill out the attached form as promptly as possible and return it by fax to 610-667-7056, or by mail in the enclosed envelope.
Kessler Topaz Meltzer & Check, LLP
James Maro, Esq. or Adrienne Bell, Esq.
280 King of Prussia Road
Radnor, PA 19087 1-888-299-7706 (toll free) or 1-610-667-7706
Or by e-mail at firstname.lastname@example.org