Attorney Advertising. Notice is hereby given that a class action has been commenced in the United States District Court for the Southern District of New York on behalf of all persons who acquired the 6.375% ING Perpetual Hybrid Capital Securities ("6.375% Securities") and/or the 8.50% ING Perpetual Hybrid Capital Securities ("8.50% Securities") (NYSE: ING) (NYSE: ISF) (NYSE: IGK) (collectively, the "Securities") of ING Groep N.V. ("ING" or the "Company") pursuant or traceable to a false registration statement and two prospectuses (collectively, the "Registration Statement") issued in connection with the Company's June 2007 and June 2008 offerings of the Securities, respectively (the "Offerings").

Stull, Stull & Brody has substantial experience representing employees who suffered losses from purchases of their employer's stock in their 401(k) plans. If you bought ING stock through your ING retirement account and have information or would like to learn more about these claims, please contact us.

The complaint charges ING, certain of its affiliates, certain of its officers and directors, the underwriters of the Offerings and its auditor with violations of the Securities Act of 1933. The action seeks to recover damages on behalf of all persons who acquired the 6.375% Securities and/or the 8.50% Securities of ING pursuant or traceable to the Registration Statement issued in connection with the Company's June 2007 and June 2008 Offerings (the "Class").

The complaint alleges that defendants consummated the Offerings pursuant to the false and misleading Registration Statement and Prospectuses. Specifically, ING sold 41,800,000 6.375% Securities at $25 per share for proceeds of over $1 billion in the June 2007 Offering and 80 million 8.50% Securities at $25 per share for proceeds of approximately $2.0 billion in the June 2008 Offering. The Registration Statement/Prospectuses incorporated ING's financial results for 2005/2006 and 2006/2007. Then, after the Offerings were completed, ING announced (EURO)2 billion in impairment charges associated with its exposure to bad loans, mortgage-related securities and other "pressurized" assets, causing the prices of the Securities issued in the Offerings to decline.

According to the complaint, the true facts which were omitted from the Registration Statement were: (a) defendants' assets, including loans and mortgage-related securities, were impaired to a much larger extent than the Company had disclosed; (b) defendants failed to properly record losses for impaired assets; (c) the Company's internal controls were inadequate to prevent the Company from improperly reporting the value of its assets; and (d) ING was not as well capitalized as represented, and, notwithstanding the billions of dollars raised in the Offerings, the Company would have to raise an additional (EURO)10 billion by selling equity in the Company to the Dutch government.

If you purchased or otherwise acquired ING securities pursuant or traceable to the Registration Statement, you may wish to move the Court to serve as lead plaintiff. Requests to be appointed lead plaintiff must be filed by no later than April 6, 2009.

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. Under certain circumstances, one or more class members may together serve as "lead plaintiff." Your ability to share in any recovery is not, however, affected by the decision whether or not to serve as a lead plaintiff. You may retain Stull, Stull & Brody, or other counsel of your choice, to serve as your counsel in this action. Stull, Stull & Brody has litigated many class actions for violations of securities laws in federal courts over the past 40 years and has obtained court approval of substantial settlements on numerous occasions. Stull, Stull & Brody maintains offices in New York and Los Angeles.

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 Aaron Brody, Esq. at Stull, Stull & Brody by e-mail at SSBNY@aol.com, by calling toll-free 1-800-337-4983, or by fax at 212/490-2022, or by writing to Stull, Stull & Brody, 6 East 45th Street, New York, NY 10017. You can also visit our website at www.ssbny.com.

Attorney Advertising. Prior Results Do Not Guarantee A Similar Outcome.

Contact: Aaron Brody, Esq. Stull, Stull & Brody ssbny@aol.com toll-free 1-800-337-4983 fax to 1-212-490-2022 Stull, Stull & Brody 6 East 45th Street New York, NY 10017 www.ssbny.com

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