Royal Dutch Shell Group .com

The law firm of Berger & Montague, P.C. has filed a securities fraud class action complaint against Royal Dutch Petroleum Company


Royal Dutch Petroleum and Shell Transport (NYSE: RD)


Class Period: 12/03/99 - 01/09/04

Lead Plaintiff Deadline: 03/26/04


The law firm of Berger & Montague, P.C. has filed a securities fraud class action complaint against Royal Dutch Petroleum Company ("Royal Dutch") and The Shell Transport Company ("Shell") on behalf of investors. Filed in the U.S. District Court for the District of New Jersey, the complaint asserts claims on behalf of investors who purchased publicly traded securities, including ordinary shares traded in overseas markets and American Depository Receipts trading on the New York Stock Exchange, of Royal Dutch (NYSE:RD) and/or Shell (NYSE:SC) during the period from December 3, 1999 through January 9, 2004 (the "Class Period").

The complaint alleges that defendants' deliberately or recklessly violated accounting rules and guidelines set by the Securities and Exchange Commission and the oil and gas industry which resulted in an enormous and shocking overstatement of oil and gas reserves. During the Class Period, Royal Dutch and Shell's financial statements and other public documents reported certain reserves as "proved reserves," an industry term used to define the estimated quantities of oil and gas which geological and engineering data demonstrate with reasonable certainty to be recoverable in future years from known reservoirs under existing economic and operating conditions. In fact, despite this claim of "reasonable certainty," and unbeknownst to investors, a full 20 percent of the reserves classified as "proved" by Royal Dutch and Shell did not meet SEC and industry requirements necessary to be classified as "proved." In this way, the defendants were able to materially and artificially inflate a key measure of the companies' financial position and competitive standing. As a result of these material misrepresentations, Royal Dutch and Shell's true value in the marketplace was severely overstated.


On January 9, 2004, Royal Dutch announced that it was going to write-down its proved oil and gas reserves by 20%, or 3.9 billion barrels, from 19.5 billion barrels to 15.6 billion barrels. The write-down prompted a former SEC chief accountant to state: "(T)he revision, looked like more than a mistake. A 20% restatement of proven reserves is a humongous error(.) . . . For a company like Shell to have missed its proven reserves by that much is not an oversight. It's an intentional misapplication of the SEC's rules." Following the announcement, Royal Dutch ADRs fell 7.87% from $52.76 to $48.61 on the NYSE and Royal Dutch ordinary shares fell by 7.10% from the U.S. equivalent of $52.91 to $49.15 on the Amsterdam exchange. Shell ADRs dropped 6.96% from $44.81 to $41.69 on the NYSE and Shell ordinary shares dropped 6.84% on the London exchange from the U.S. equivalent of $7.36 to $6.86. The Chairman of the Royal Dutch and Shell has since resigned.


If you purchased Royal Dutch and/or Shell securities during the Class Period (December 3, 1999 thru January 9, 2004), you may, no later than March 26, 2004, move to be appointed as a Lead Plaintiff. A Lead Plaintiff is a representative party that acts on behalf of other class members in directing the litigation. The Private Securities Litigation Reform Act of 1995 directs Courts to assume that the class member(s) with the "largest financial interest" in the outcome of the case will best serve the class in this capacity. Courts have discretion in determining which class member(s) have the "largest financial interest," and have appointed Lead Plaintiffs with substantial losses in both absolute terms and as a percentage of their net worth. If you have sustained substantial losses in Royal Dutch and/or Shell securities during the Class Period, please contact Berger & Montague, P.C. at for a more thorough explanation of the Lead Plaintiff selection process.


If you purchased Royal Dutch Petroleum and Shell Transport securities during the Class Period, or have any questions concerning this notice or your rights with respect to this matter, please contact:


Glen Abramson

Diane R. Werwinski, Investor Relations Manager

Berger & Montague, P.C.

1622 Locust Street

Philadelphia, PA 19103

Phone: 888-891-2289 or 215-875-3000

Fax: 215-875-5715





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