The following summarizes many such settlements and judgments, described in published reports:

1. A $2.97 billion settlement in consolidated securities class action litigation against Tyco International Ltd. and its directors and officers. The litigation alleged that the defendants overstated the company's income from 1999 through 2002 by $5.8billion, resulting in the criminal convictions of the company's CEO (Kozlowski) and CFO (Schwartz). As part of the settlement, the company assigned to the plaintiffs the company's claims against its auditor relating to the accounting fraud.

2. A $2.83 billion settlement in a shareholder class action against Cendant Corp. and its directors and officers. The lawsuit alleged that the defendants artificially inflated the company's stock price through an accounting fraud, which resulted in the company restating its financial statements for several years. The lead plaintiffs in the litigation were three of the country's largest public pension funds, New York State Common Retirement Fund, New York City's Pension Funds, and the California Public Employees Retirement System.

3. A $2.7 billion settlement in securities class action lawsuits against Nortel Networks Corporation and its directors and officers. The litigation alleged that the defendants misrepresented the financial performance and condition of the company, resulting in two restatements by the company and the discharge of the company's top three executives. The settlement consists of $575 million cash from the company, $228.5 million from insurers and 14.5% of the company's outstanding common shares.

4. A $2.4 billion settlement in a securities class action lawsuit against Time Warner and its directors and officers. The lawsuit alleged that the defendants misrepresented material facts in connection with Time Warner's merger with AOL, including inflated revenues and improper accounting practices. The company's auditor, Ernst & Young, agreed to pay an additional $100million. The settlement does not include several large “opt-out” claims or shareholder derivative lawsuits.

5. A $1.1 billion settlement in a securities class action lawsuit against Royal Ahold NV and its directors, officers and other professionals. The lawsuit arose out of accounting problems at Ahold's U.S. Foodservices subsidiary which required the restatement of the Company's financial statements for more than two years. The settlement is reportedly the largest settlement paid by a non-U.S. company in securities class action litigation, and follows a ruling by the U.S. District Court that non-U.S. shareholders of Ahold who purchased their shares on securities exchanges located outside the U.S. could participate in the U.S. litigation.

6. A $960 million settlement in a consolidated securities class action litigation against McKesson Corp. and its directors and officers. The litigation alleged the defendants misrepresented material information in connection with its acquisition of HBO & Co. for $12 billion in stock and the company's subsequent restatement of earnings related to software sales due to improper revenue recognition. Four former executives pled guilty to various criminal charges relating to the wrongdoing, and criminal charges remain pending against other company officials.

7. An $895 million settlement in a securities class action lawsuit against UnitedHealth Group and its directors and officers. The lawsuit alleged that the defendants misrepresented and failed to disclose various information relating to stock option backdating practices which ultimately resulted in the company restating its financial statements for several years with more than $1.5billion of expense adjustments. The class action settlement was in addition to (i) earlier settlements by individual officers with the SEC and in a shareholder derivative suit, pursuant to which certain senior officers personally disgorged approximately $930 million, and (ii) a $17 million settlement in a related ERISA tag-along class action lawsuit. The securities class action settlement did not include a settlement of claims against the company's former CEO and former general counsel.

8. A $750 million settlement in a securities class action lawsuit against Xerox and its directors, officers and auditor. The lawsuit alleged that the defendants misrepresented the financial performance and condition of the company, resulting in the company restating five years of operating results. $670 million of the settlement is being paid by the company in five installments and $80 million is being paid by the outside auditor (KPMG). In addition, the company previously paid a $10 million penalty to settle SEC charges and created a $125 million reserve for potential liability in three related lawsuits.

9. A $600 million settlement in securities class action litigation against Cardinal Health, Inc. and its directors and officers. The litigation alleged that the defendants misrepresented information relating to the company's financial performance, resulting in a three-year restatement of the company's financial reports. The settlement does not include related ERISA stock drop litigation and derivative lawsuits.

10. A $600 million settlement in securities fraud, ERISA and derivative lawsuits against Lucent Technologies and its directors and officers. The lawsuits arose from Lucent's December 2000 announcement that its pro forma fourth quarter results had to be substantially reduced to reflect the fact that revenue had been improperly recognized. The lawsuits further alleged that the defendants misrepresented and failed to disclose material information regarding the company's financial condition and performance, as well as business prospects. The company's stock price dropped during the class period from more than $80/share to less than $12/share, reportedly giving rise to the largest damage exposure in securities class action history.

11. A $490 million settlement in a securities fraud lawsuit against Bank of America and certain of its directors and officers. The lawsuits alleged that both prior and after the merger between Bank America and Nations Bank, the defendants made misrepresentations regarding the effects of the merger, as well as the extent of loss exposure for certain loans or investments. Approximately $200 million of the settlement was funded by insurance.

12. A $475 million settlement in a securities class action lawsuit against Merrill Lynch and its directors and officers. The lawsuit alleged the defendants failed to fully and accurately disclose the company's exposure to subprime debt and likely impact of the deteriorating subprime mortgage market. A related ERISA tag-along lawsuit against the company and fiduciaries of its retirement plans was settled for $75 million.

13. A $468 million settlement in a consolidated securities class action lawsuit against Dynegy and its directors and officers. The lawsuit alleged the defendants issued false and misleading information related to “Project Alpha,” a structured natural gas transaction entered into by the company in 2001. Several company employees either pled guilty or were convicted of criminal wrongdoing in connection with that transaction. $150 million of the settlement was funded by D&O insurance, $250 million of the settlement was paid by the company in cash, and $68 million of company common stock was issued to class members.

14. A $457 million settlement in a securities class action against Waste Management and its directors and officers. The lawsuit alleged that the defendants misrepresented material facts regarding the company's 1998 merger with USA Waste Services, Inc. and a 1999 accounting scandal which resulted in the company twice revising reported earnings and taking a $1.8 billion write-off.

15. A $454.5 million jury verdict in a lawsuit by two individuals against Comp USA, its former CEO, a principal shareholder and two affiliated companies of the shareholder. The plaintiffs in the lawsuit allegedly entered into an agreement with CompUSA to open CompUSA stores in Mexico. The jury found the defendants improperly breached that agreement and awarded the franchising deal to the principal shareholder defendant. The jury allocated the total damage award 65% to the former CEO, 25% to the principal shareholder, and 10% each to two affiliated companies of the principal shareholder. The court subsequently reversed the verdict against CompUSA and its former CEO, and reduced to $121 million the judgment against the principal shareholder.

16. A $445 million settlement in a securities class action and derivative litigation against HealthSouth Corp. and its directors and officers. The litigation alleged senior officers engaged in a massive accounting fraud for many years, ultimately resulting in the company restating its financial statements and the company stock dropping from $31 per share to .09¢ per share. The settlement was reportedly funded with $230 million from D&O insurance and $215 million in common stock and warrants from the company. Claims against the company's auditors and underwriters were not part of the settlement. The settlement was in addition to a $100 million settlement with the SEC.

17. A $410 million settlement in a securities class action against Raytheon Company and its directors and officers. The lawsuit alleged accounting irregularities in connection with the Raytheon Engineering & Constructors division and a failure to take appropriate write-downs on a plane refurbishment program for the U.S. Navy. The settlement calls for payment of $200 million cash, to be funded partially by insurance, and warrants valued at $210 million. The company's auditors, PricewaterhouseCoopers, have agreed to pay an additional $50 million to settle the claims against them.

18. A $400 million settlement in a securities class action against Qwest Communications International, Inc. and its directors and officers. The lawsuit alleged that between 1999 and 2002, Qwest fraudulently recognized over $3.8 billion in revenue and excluded $231 million in expenses as part of a scheme to meet revenue and earnings projections. The settlement dismisses claims against the company and all of the D&O defendants except the former CEO and CFO. The class settlement is in addition to a $250 million penalty which was paid to the SEC, and a $411 million settlement with a group of investors who opted out of the class settlement.

19. A $352.6 million settlement in a securities class action lawsuit by non-U.S. shareholders against Royal Dutch Shell and its directors and officers. The lawsuit alleged misrepresentations in connection with the company's oil reserves accounting treatment of those reserves. The settlement, which is reported to be the largest securities class action settlement in Europe, is for the benefit of investors who both resided and purchased shares outside the U.S. and is in addition to a $120 million settlement by the company with the SEC in 2004 relating to the same allegations. The same proportional settlement is also being offered to investors in the United States. In a related securities class action on behalf of U.S. investors, the defendants agreed to pay an additional $118 million.”

20. A $325 million settlement in a securities fraud lawsuit and an ERISA lawsuit against certain directors and officers of Global Crossing and its subsidiaries and Plan fiduciaries. The lawsuits alleged that the defendants improperly accounted for “swap” transactions which eventually led to a massive write-down and Global Crossing's bankruptcy, although Global Crossing never restated its earnings. The D&Os allegedly sold over $1.5 billion of their personal Global Crossing stock during a three-year class period. Approximately $250 million of the settlement was funded by D&O and Fiduciary insurance, with the balance coming from Global Crossing's former Chairman ($55 million) and former law firm ($20 million).

21. A $303 million settlement in a securities class action against General Motors Corp. The lawsuit alleged that GM issued false and misleading statements regarding the company's financial condition. Deloitte & Touche, General Motor's outside auditor, will contribute $26 million towards the settlement. A related shareholder lawsuit was settled by the Company agreeing to certain governance reforms and paying a plaintiffs' attorney fee up to $7.5 million.

22. A $300 million settlement in a securities class action against Bristol-Myers Squibb Co. and its directors and officers. The lawsuit alleged that the defendants made overly optimistic statements about its investment in ImClone Systems, Inc. and the likelihood that ImClone would obtain FDA approval for one of its new drugs. Plaintiffs also alleged that the defendants overstated the company's revenue between 1999 and 2001 by $2.5 billion by offering incentives to wholesalers.

23. A $300 million partial settlement of securities class action litigation by Chrysler Corp. shareholders against Chrysler Corp., Daimler Benz and the CEO of Daimler Benz. The consolidated litigation alleged that Daimler Benz' CEO misled investors in connection with the merger of Chrysler and Daimler Benz in 1997 by stating at the time of the merger that it was a “merger of equals,” when in fact he always intended to make Chrysler a subsidiary of Daimler Benz. The CEO was allegedly motivated to make the misleading statement in order to enhance the likelihood that Chrysler shareholders and the U.S. Government would support the proposed merger and in order to avoid paying shareholders of Chrysler a premium to acquire Chrysler. Insurers reportedly paid $220 million of the settlement.

24. A $300 million settlement in a securities class action against Oxford Health Plans, Inc. and its directors and officers and auditor. The Lawsuit alleged the defendants misrepresented material information about the company's financial condition and operations, primarily as a result of a defective computer system that could not handle the HMO's billing and claims data. The auditor paid $75 million of the settlement and $225 million was paid by Oxford and its insurers.

25. A $295.1 million settlement in a securities class action lawsuit against directors, officers and securities underwriters of Delphi Corp. The litigation alleged that the defendants artificially inflated the company's share prices by issuing misleading earnings statements in years prior to the company's bankruptcy. $88.6 million of the settlement was reportedly funded by insurance companies and $204 million of the settlement represents ownership interest in the reorganized company. A related ERISA class action was settled for $47 million.

26. A $290 million settlement in a securities class action lawsuit against Williams Cos., Inc. and its officers. The lawsuit alleged the defendants failed to disclose accurate information in connection with the company's energy trading business and the spin-off of a subsidiary to public investors. The company reportedly paid between $145 million and $220 million of the settlement in cash, and the balance of the settlement was funded by insurance.

27. A $284 million judgment and settlement in a lawsuit brought by bondholders of Safety-Kleen Corp. The bondholders alleged that defendants engaged in accounting improprieties and related misrepresentations, including material overstatement of revenues and earnings. After a seven week trial, the judge directed a verdict in favor of the bondholders in the amount of $200 million against the company's former CEO and former CFO. Prior to the start of the trial, Pricewaterhouse Coopers agreed to pay $48million to settle claims against it, and former directors of the company agreed to settle claims against them for $36 million. Insurers funded the former directors' settlement.

28. A $273 million settlement in securities class action and shareholder derivative lawsuits against El PasoCorp. and its directors and officers. The lawsuits alleged wrongdoing in connection with purported wash trades, mark-to-market accounting, off-balance sheet debt, overstatement of natural gas and oil reserves, and manipulation of the California energy market. The company is contributing $48 million and its insurers are contributing $225 million. Seventeen million dollars of the total settlement was attributable to the shareholder derivative lawsuit.

29. A $259 million settlement in a shareholder class action against 3Com, U.S. Robotics, and various directors and officers of those companies. The lawsuit alleged the defendants misrepresented material facts regarding the companies' financial performance and 3Com's acquisition of U.S. Robotics. The alleged wrongdoing occurred both before and after the acquisition. Two of the lead plaintiffs were institutional investors.

30. A $230 million settlement in a shareholder derivative lawsuit against directors and officers of Computer Associates, Inc. The lawsuit alleged that the defendants breached their fiduciary duties and unreasonably jeopardized the company's financial condition by awarding to three executives $500 million in stock options. The settlement followed a ruling by the court that the three executives must return 9.5 million of the 20.25 million shares they received under what the court found to be a misinterpretation of the company's compensation plan.

31. A $220 million settlement in a securities class action lawsuit against Waste Management, Inc. and its directors and officers and auditor. The lawsuit alleged that the defendants overstated the company's profits over several years, resulting in a restatement of the company's financial statements with a $1.32 billion adjustment in previously reported profits for the preceding six years. A related shareholder derivative lawsuit was settled for approximately $23 million in total consideration.

32. A $215 million settlement in a securities class action lawsuit against Sears, Roebuck and Co. its officers. The litigation related to statements made by the defendants concerning the company's credit card business. The company expects to recover approximately $130 million of the settlement from insurers.

33. A $215 million settlement in a securities class action lawsuit against Tenet Healthcare Corp. and its directors and officers. The lawsuit alleged that the defendants misrepresented the company's business and financial performance by failing to disclose that a large portion of its revenue for the two preceding years was from Medicare reimbursements pursuant to an unsustainable practice by the company. D&O insurance reportedly paid $75 million of the settlement, and the former CEO and former COO of the company personally paid $1 million and $500,000, respectively.

34. A $200 million settlement in a securities class action lawsuit against CMS Energy and its directors and officers. The lawsuit alleged defendants issued false financial statements by including $5 billion of revenue from “round-trip” or “wash” trades which lacked economic substance. Insurers paid $76.5 million of the settlement, and CMS paid $123.5 million.

35. An approximately $195.5 million settlement in a securities class action against Rite Aid Corporation and its directors, officers and outside auditor. The lawsuit alleged that the defendants engaged in various earnings-inflating and expense-deflating accounting practices, which resulted in the company restating its financial statements for three years and removing approximately $1.5 billion of after-tax earnings from those financial statements. The settlement was funded with $43.5 million in cash paid by the company's insurers and 20 million shares of common stock, with a guaranteed minimum value of $149.5 million. Claims against the former chairman, CFO and president of the company, as well as the company's auditor, were not released as part of the settlement and were subsequently pursued by plaintiffs.

36. A $193 million settlement in a securities class action lawsuit against PNC Financial Services Group and its officers. The lawsuit alleged that the defendants misled investors regarding the financial condition of PNC by “selling” $762million in bad corporate loans to three partnerships created by PNC with AIG. PNC eventually restated its financial statements, reducing earnings by $155million.

37. A $190 million settlement in securities class action litigation against Motorola, Inc. and its directors and officers. The litigation alleged that the defendants failed to properly disclose material information regarding the company's dealings with Telsim (a foreign vendor which was heavily financed by Motorola) and the company's financial exposures relating to transactions with Telsim.

38. A $179 million settlement of the securities class action claims against former outside directors of Enron Corp. The claims alleged the defendants failed to disclose in securities offering documents the true financial condition and performance of Enron, which ultimately filed bankruptcy. $13 million of the settlement amount is being contributed personally by the outside director defendants as disgorgement of gain they realized on their sale of Enron stock. The settlement does not settle any of the claims against numerous other former officers and directors.

39. A $165 million settlement in a state court breach of fiduciary duty class action against directors of Digex, Inc. The lawsuit alleged that the defendants breached fiduciary duties owing to Digex shareholders by agreeing to merger terms which were inadequate to the shareholders. The settlement was funded entirely with stock in the acquiring company (World Com).

40. A $162 million settlement in a securities class action lawsuit against Dollar General Corporation and its directors and officers. The lawsuit alleged that the defendants materially misrepresented financial information regarding the company, ultimately resulting in the company restating its financial statements for fiscal 1998, 1999 and 2000. During that time period, the company raised $200 million in a debt offering and certain individual defendants sold nearly $300 million in company securities through a registered offering.

41. A $160 million settlement in a securities class action litigation against Brocade Communications and certain former directors and officers. The litigation alleged that the defendants misrepresented and omitted material information from 2000 to 2004 relating to the company's stock option backdating practices. The settlement followed the criminal conviction of the company's CEO (who was sentenced to 21 months in jail and fined $15 million) and the company's former personnel director (who was sentenced to four months in jail and fined $1.25 million).

42. A $160 million jury verdict against Cell Tech International, Inc. and two of its officers in a shareholder derivative claim and a direct breach of contract claim by the company's founder, Daryl Kollman. The lawsuit alleged the plaintiff was wrongly fired by the company after a change-in-control, and the defendants breached an agreement to register stock owned by the plaintiff for public sale.

43. A $150 million settlement in securities class action litigation against TXU Corp. and its directors and officers. The litigation alleged misstatements regarding the company's financial performance and condition. At least $66 million of the settlement was paid by D&O insurance.

44. A $150 million settlement in a securities class action against Broadcom Corp. and certain of its former directors and officers. The lawsuit alleged that Broadcom improperly accounted for millions of dollars in warrants issued to customers who purchased specific amounts of Broadcom products. Allegedly, company officials sold more than $80 million in stock prior to revealing information about the warrants, at which time Broadcom's share price dropped 35 percent. Insurers reportedly paid $40 million of that settlement.

45. A $145.5 million settlement in securities class action and shareholder derivative litigation against DPL, Inc. and its directors, officers and auditor. The litigation arose out of DPL's investments in numerous Central America ventures, which ultimately resulted in more than $200 million of investment loss to DPL. Plaintiffs alleged that the defendants failed to properly disclose the existence and speculative nature of the investments, the true value of the investments, and the mismanagement of the company's investment portfolio. Insurers reportedly paid $70 million of the settlement, and the auditor reportedly contributed $5.5 million to the settlement.

46. A $144 million settlement in a securities class action and a shareholder derivative lawsuit against Charter Communications, Inc. and its directors and officers. The lawsuit alleged that Charter used misleading accounting practices causing it to issue false and misleading financial statements concerning its operations and prospects. Insurers contributed $64 million to the settlement with the remainder to be paid in stock and warrants.

47. A $142 million settlement in a shareholder class action against Informix Corporation, its directors and officers and accounting firm. The lawsuit, which purportedly resulted in the largest securities fraud settlement in the history of Silicon Valley, alleged that the defendants violated the federal securities laws by issuing materially false financial statements for three and one-half years. Those financial statements were eventually restated. Fifty-one million dollars of the settlement was paid in cash and the remaining $91 million was paid in company stock. The defendant accounting firm paid $34 million of the $51 million cash portion of the settlement.

48. A $139 million settlement in a securities class action lawsuit against Symbol Technologies, Inc. and its directors and officers. The lawsuit alleged that defendants fraudulently misrepresented the company's revenues and profits resulting in artificial inflation of its securities. The terms of the settlement require the company to distribute to the class common stock worth at least $96.25 million and $38.75 million in cash. The company's former CEO will personally pay $4 million cash. The settlement does not resolve related shareholder litigation against Symbol's auditor.

49. A $138 million settlement in a securities class action against Biovail Corp. and its directors and officers. The litigation alleged that the defendants made a series of materially false and misleading statements about the company's publicly reported financial condition and performance.

50. A $137.5 million settlement in a securities class action litigation against Coca-Cola Co. and its directors and officers. The lawsuit alleged that the defendants misrepresented and omitted material information about the company's business and financial results in 1999 and 2000 by, among other methods, boosting revenues through forcing some of the company's key bottlers to accept excessive beverage concentrate.

51. A $130 million settlement in a securities class action litigation against Doral Financial Corp. and its directors and officers. The litigation alleged that the defendants improperly accounted for its derivative portfolio of interest-only strips. The settlement, which was contingent upon the company's ability to obtain financing for its continuing business operations, was reportedly composed of $95million from the company, $34 million from the D&O insurers and $1million from one or more individual defendants.

52. A $122 million settlement in a securities class action against Mattel, Inc. and its directors and former officers. The lawsuit alleged the defendants misrepresented material information relating to Mattel's acquisition of The Learning Co. Mattel acquired that company for $3.5 billion in stock and was forced to sell the company one year later for no cash and a portion of any future profits from the company.

53. A $120 million settlement in a securities class action against Bank One and its directors and officers. The lawsuit arose out of Bank One's merger with First Chicago National Bank. Defendants allegedly misrepresented Bank One's financial results upon which plaintiffs relied in approving the merger.

54. A $120 million settlement in a securities class action against Conseco, Inc. and its directors and officers. The lawsuit alleged that the defendants misrepresented the company's financial results for 1999.

55. A $115.5 million settlement of shareholder class actions against Philip Morris Companies, Inc. and its D&Os. The lawsuits alleged the defendants failed to disclose material information regarding the addictive effects of nicotine in cigarettes and regarding alleged manipulation of the company's sales performance through “channel stuffing” of its products.

56. A $115 million settlement in a securities class action against Interpublic Group and its directors and officers. The lawsuit arose from Interpublic Group's five year restatement of its financial results correcting inter-company charges wrongly declared as income for one of its European offices. The settlement is to be funded by $20 million in cash and $95 million in Interpublic Group common stock.

57. A $115 million settlement in a shareholder derivative lawsuit on behalf of AIG against former officers of AIG. The lawsuit alleged the defendants breached their fiduciary duties to AIG by approving payments of allegedly excessive commissions to C.V. Starr, Inc., an entity owned by the defendants. $85.5 million of the settlement was reportedly paid by insurance, and the balance was paid by the defendant.

58. A $114.5 million settlement in a securities class action lawsuit against SCOR S.E. and its directors and officers. The lawsuit, which was brought on behalf of shareholders of a reinsurance company acquired by SCOR (i.e., Converium Holding Ltd.), alleged that Converium misrepresented and omitted material information in various public disclosures relating to its financial condition and performance. The settlement resolved claims by both U.S. investors and non-U.S. investors, and resolved litigation pending in both the U.S. and in the Netherlands.

59. A $113.7 million settlement in a securities class action lawsuit against MicroStrategy, Inc. and its directors and officers. The lawsuit alleged that the defendants misrepresented the financial condition and performance of the company, resulting in a restatement of the company's financial statements for three years. As part of the settlement, the company issued notes to the class members for $80.5 million in cash and a distribution of company stock guaranteed to be worth at least $16.5 million. Some of the company stock was paid directly by the D&O defendants. The cash portion of the settlement was payable in five years, although the company is required to make interim payments of $3 million every six months.

60. A $111 million settlement of shareholder class action and derivative litigation against IKON Office Solutions and its directors and officers. The lawsuits alleged that the defendants artificially inflated the company's stock price by issuing misleading financial reports from 1996 through 1998, during which period the company acquired 220 corporations. The settlement does not resolve related shareholder litigation against IKON's auditor.

61. A $110 million settlement in a consolidated securities class action lawsuit against CVS Corp. and its Chief Executive Officer. The lawsuit alleged that the defendants violated the federal securities laws by delaying discounts on merchandise, waiting several months to disclose that the company intended to close 200 underperforming stores, and delaying disclosure that a pharmacist shortage would have a negative impact on company earnings. The settlement was funded “primarily” by insurance.

62. A $100 million settlement in a securities class action against AT&T and its directors and officers. The lawsuit alleged that the defendants issued false and misleading forward-looking statements regarding the company's business and financial prospects. The settlement occurred one week after the jury trial in the lawsuit commenced.

63. A $100 million settlement in a securities class action lawsuit against Honeywell International, Inc. and its directors and officers. The lawsuit alleged that the defendants misrepresented the success of Honeywell's merger with Allied Signal, Inc., thereby artificially inflating the price of Honeywell's securities. The lead plaintiffs were institutional investors. The company's insurers reportedly paid $85 million of the settlement.

64. A $92.5 million settlement of federal and state shareholder class actions against The Boeing Company and its directors and officers. The lawsuits alleged that the defendants misrepresented and concealed information about the status of Boeing's commercial airplane production problems and the financial results of those operations. The entire cash settlement was paid by Boeing's D&O insurers.

65. A $54 million settlement of the securities class action claims against the outside directors of WorldCom, Inc. $36 million of the settlement amount will be funded by D&O insurance, with the balance being paid by the settling directors personally. The class action lawsuit alleged a “massive” accounting fraud which the Court stated would be easy “for any party” to prove. The settlement does not settle claims against some of the defendant officers.