IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
In re NEWS CORPORATIONSHAREHOLDER DERIVATIVELITIGATION))))ConsolidatedC.A. No. 6285-VCN
VERIFIED AMENDED CONSOLIDATED SHAREHOLDER DERIVATIVEAND CLASS ACTION COMPLAINT
Co-Lead Plaintiffs The Amalgamated Bank, as Trustee for the LongViewLargeCap 500 Index Fund, LongView LargeCap 500 Index VEBA Fund, LongViewQuantitative LargeCap Fund, and LongView Quantitative LargeCap VEBA Fund(“Amalgamated Bank”), Central Laborers Pension Fund (“Central Laborers”), andplaintiff New Orleans Employees’ Retirement System (“NOERS”) (“Plaintiffs”), by andthrough their undersigned counsel, assert this action derivatively on behalf of NewsCorporation (“News Corp” or the “Company”) and directly on behalf of themselves andall similarly situated public shareholders of News Corp against defendants RupertMurdoch, James Murdoch, Lachlan Murdoch, Chase Carey, David F. DeVoe, Joel Klein,Arthur M. Siskind, Rod Eddington, Andrew S.B. Knight, Thomas J. Perkins, PeterBarnes, José María Aznar, Natalie Bancroft, Kenneth E. Cowley, Viet Dinh, and John L.Thornton (the “Individual Defendants,” “Defendants” or the “Board”). Plaintiffs makethe following allegations upon knowledge as to themselves and upon information andbelief (including the investigation of counsel and review of publicly availableinformation) as to all other matters, and allege as follows.