
* CSFB, as the lead underwriter of hot IPOs for companies such as VA Linux Systems Inc., Selectica, Gadzooks Networks, and MP3.com, had control over the allocation of most of the shares in these IPOs. In exchange for some of the highly- coveted stock in such hot IPOs, CSFB wrongfully extracted from certain customers a large share of the huge profits those customers made in quickly selling (or flipping) the IPO stock bestowed on them by CSFB. * Specifically, CSFB allocated shares of IPOs to more than 100 customers who, in return, funneled between 33 and 65 percent of their IPO profits to CSFB. These customers typically flipped the stock on the day of the IPO, often gaining tremendous profits. They then transferred a share of their flipping profits to CSFB by way of excessively high brokerage commissions (ranging from $0.19 per share to $3.15 per share – in contrast to the typical rate of about $0.06 per share). The customers paid these commissions on uneconomic, limited-risk trades in highly liquid, exchange- traded shares unrelated to the IPO shares – trades that they effected for the sole purpose of paying IPO flipping profits back to CSFB. * The profit-sharing activity was pervasive at CSFB. Senior executives who were in managerial and supervisory roles knew of the practices described in the complaint, encouraged many of the practices described in the complaint, directed CSFB employees to urge customers to maintain specified ratios of commissions to IPO profits, and, in some instances, personally engaged in some of the practices described in the complaint. * CSFB employees informed the relevant customers, both implicitly and explicitly, that they were expected to pay back to CSFB a portion of profits earned on their IPO flipping in order to continue to receive allocations. Customers who refused to funnel a portion of their profits to CSFB received smaller allocations, and in some instances were denied allocations altogether. The prevalence of CSFB's abusive practices is reflected in numerous e-mail messages and other communications, examples of which are cited in the complaint. * The profit-sharing customers received no more than 10 percent of the IPO stock allocated by CSFB in each offering. IPO flipping was so profitable, however, that CSFB wrongfully obtained tens of millions of dollars in IPO profits through this improper conduct