Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
3Activity
0 of .
Results for:
No results containing your search query
P. 1
Kosmos Energy Suit

Kosmos Energy Suit

Ratings: (0)|Views: 1,066 |Likes:

More info:

Categories:Topics, Art & Design
Published by: Elizabeth Souder-Philyaw on Aug 02, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

08/02/2012

pdf

text

original

 
UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF TEXASDALLAS DIVISIONWILLIAM TARLETON, Individually and OnBehalf of All Others Similarly Situated,Plaintiff,vs.KOSMOS ENERGY LTD., BRIAN F. MAXTED,W. GREG DUNLEVY, SYLVIA MANOR, JOHNR. KEMP, DAVID I. FOLEY, JEFFREY A.HARRIS, DAVID B. KRIEGER, PRAKASH A.MELWANI, ADEBAYO O. OGUNLESI, CHRISTONG, CHRISTOPHER A. WRIGHT, THEBLACKSTONE GROUP L.P., WARBURGPINCUS LLC, CITIGROUP GLOBAL MARKETSINC., BARCLAYS CAPITAL INC., CREDITSUISSE SECURITIES (USA) LLC, BNPPARIBAS SECURITIES CORP., SG AMERICASSECURITIES, LLC, CREDIT AGRICOLESECURITIES (USA) INC., HSBC SECURITIES(USA) INC., NATIXIS BLEICHROEDER LLC,JEFFERIES & COMPANY, INC., RBC CAPITALMARKETS, LLC and HOWARD WEILINCORPORATED,Defendants.))))))))))))))))))))))))))))CIVIL ACTION NO. 3:12-cv-2612JURY TRIAL DEMANDEDCLASS ACTION
ORIGINAL CLASS ACTION COMPLAINTFOR VIOLATION OF THE FEDERAL SECURITIES LAWS
Plaintiff, William Tarleton (“Plaintiff”), alleges the following based upon theinvestigation of Plaintiff’s counsel, which included, among other things, a review of defendants’public documents, conference calls and announcements, United States Securities and ExchangeCommission (“SEC”) filings, wire and press releases published by and regarding KosmosEnergy Ltd. (“Kosmos” or the “Company”) and securities analysts’ reports and advisories about
Case 3:12-cv-02612-P Document 1 Filed 08/01/12 Page 1 of 24 PageID 1
 
 ORIGINAL CLASS ACTION COMPLAINTFOR VIOLATION OF THE FEDERAL SECURITIES LAWS PAGE 2
the Company. Plaintiff believes that substantial additional evidentiary support will exist for theallegations set forth herein after a reasonable opportunity for discovery.1.
 
This is a federal class action on behalf of purchasers of the common stock of Kosmos, who purchased or otherwise acquired Kosmos common stock pursuant and/or traceableto the Company’s Initial Public Offering (the “IPO” or the “Offering”), seeking to pursueremedies under the Securities Act of 1933 (the “Securities Act”).
NATURE OF THE ACTION AND OVERVIEW
2.
 
Kosmos is an independent oil and gas exploration and production companyfocused on under-explored regions in Africa. Formed in 2003, Kosmos acquired its currentexploration licenses and established a new, major oil province in West Africa with the discoveryof the Jubilee Field in 2007. The Jubilee Field was the first of seven discoveries offshore Ghana,and “was one of the largest oil discoveries worldwide in 2007 and the largest find offshore WestAfrica in the last decade.”3.
 
On or about May 11, 2011, the Company conducted its IPO. In connection withthe IPO, the Company filed a Registration Statement and Prospectus (collectively referred tohereinafter as the “Offering Materials”) with the SEC.4.
 
The IPO was a financial success for Kosmos and the Underwriter Defendants(defined below), as they raised over $621 million by selling over 34.5 million shares of stock toinvestors at a price of $18.00 per share. Kosmos received net proceeds from the IPO of $580.4million (after underwriting discounts, commissions and offering expenses).5.
 
However, the Offering Materials were negligently prepared and, as a result,contained untrue statements of materials facts, omitted to state other facts necessary to make the
Case 3:12-cv-02612-P Document 1 Filed 08/01/12 Page 2 of 24 PageID 2
 
 ORIGINAL CLASS ACTION COMPLAINTFOR VIOLATION OF THE FEDERAL SECURITIES LAWS PAGE 3
statements made not misleading, and were not prepared in accordance with the rules andregulations governing their preparation.6.
 
Specifically, the Offering Materials misstated the progress that Kosmos had madein developing the Jubilee Field. The development of the Jubilee Field, and the accuraterepresentation of that development, was material information and was discussed repeatedly in theOffering Materials.7.
 
As of the date of this complaint, the price of Kosmos’ stock has significantlydeclined from its IPO price of $18.00 per share and currently trades below $10.00 per share.8.
 
The Complaint alleges that the Offering Materials filed in connection with theIPO were materially misleading when issued because, contrary to numerous statements made inthe Offering Materials, oil production from the Jubilee Field was not on track to reach its designcapacity of 120,000 barrels of oil per day (“bopd”) by the third quarter of 2011. Rather, andagain in stark contrast to statements in the Offering Materials, several of the Jubilee oil wellswere not producing as expected due to design defects with the oil wells – defects that existedprior to, and at the time of, the Company’s IPO.9.
 
Investors subsequently learned that these design defects would cost Kosmoshundreds of millions of dollars to remediate, and would keep the Jubilee oil wells fromproducing as they were expected to for several years.
JURISDICTION AND VENUE
10.
 
The claims asserted herein arise under and pursuant to Sections 11, 12(a)(2), and15 of the Securities Act (15 U.S.C. §§ 77k and 77o).11.
 
This Court has jurisdiction over the subject matter of this action pursuant toSection 22 of the Securities Act (15 U.S.C. § 77v).
Case 3:12-cv-02612-P Document 1 Filed 08/01/12 Page 3 of 24 PageID 3

Activity (3)

You've already reviewed this. Edit your review.
1 hundred reads
1 thousand reads

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->