Royal Dutch Shell Group .com

(MARKET WIRE) NEW YORK: Class Action Lawsuit Commenced Against the Royal Dutch/Shell Group

New York 04/02/2004


Royal Dutch Petroleum Company, and The Shell Transport and Trading Company, PLC by Bernstein Liebhard & Lifshitz, LLP


A securities class action lawsuit was commenced in the District of New Jersey on behalf of all purchasers of American Depository Receipts ("ADRs") of Royal Dutch Petroleum Company ("Royal Dutch") (NYSE: RD) and/or The Shell Transport and Trading Company, PLC ("Shell Transport") (NYSE: SC), collectively "Royal Dutch/Shell") between December 3, 1999 and January 9, 2004, inclusive (the "Class Period"). A copy of the Complaint is available from the Court or from Bernstein Liebhard & Lifshitz, LLP. Please visit our website at or contact us at (800) 217-1522 or by e-mail at


Plaintiff alleges that defendants Royal Dutch, Shell Transport, Shell Petroleum N.V., Shell Petroleum Limited, Maarten van der Bergh, Judy Boynton, Malcolm Brinded, S.L. Miller, Harry J.M. Roels, Paul D. Skinner, M. Moody-Stuart, Jeroen van der Veer, and Philip R. Watts violated Sections 10(b) and 20(a) of the Securities Exchange Act of 1934, and Rule 10b-5 promulgated thereunder. Between December 3, 1999 and January 9, 2004, the defendants issued a series of material misrepresentations to the market concerning the Company's financial standing. More specifically, the defendants' statements during the Class Period were materially false and misleading because they failed to disclose and/or misrepresented the following adverse facts, among others: (1) Royal Dutch/Shell had overstated its proved oil and gas reserve figures by 20%; (2) Royal Dutch/Shell accomplished the overstatement by including in its proved oil and gas reserves figures, when its venture partners did not, estimates from the Gorgon Joint Venture in Australia and the Nigerian Projects in Africa when such projects did not meet industry and Securities and Exchange Commission standards for proved reverses; (3) the inclusion of Gorgon Joint Venture in Australia and the Nigerian Projects in Africa and other projects was accomplished through the booking of its proved oil and gas reversed figures on the basis of initial letters of intent rather than on the basis of when such projects had been contracted; and (4) as a result, Royal Dutch/Shell's true market value was materially overstated at all relevant times.


On January 9, 2004, Royal Dutch/Shell announced that, following internal reviews, some proved hydrocarbon reserves would be re-categorized. The total non recurring re-categorization, relative to the proved reserves as stated at December 31, 2002, represented 3.9 billion barrels of oil equivalent ("boe") of proved reserves, or 20% of proved reserves at that date. Over 90% of the total change is a reduction in the proved undeveloped category; the balance is a reduction in the proved developed category. Additionally, the Company stated that of the re-categorization, two thirds (2.7 billion barrels) related to crude oil and natural gas liquids, and one third (1.2 billion boe or 7.2 trillion standard cubic feet) to natural gas. Moreover, Royal Dutch/Shell indicated that the FAS69 standardized measure of discounted future cash flows associated with the proved reserves would be impacted.


On news of this, shares of Shell Transport fell 6.9%, or $3.12 per share, on heavy volume to close at $41.69 per share on January 9, 2004. Additionally, shares of Royal Dutch fell 7.8%, or $4.15 per share, on heavy volume to close at $48.61 per share on January 9, 2004.


Plaintiff seeks to recover damages on behalf of all those who purchased or otherwise acquired Royal Dutch/Shell securities during the Class Period. If you purchased or otherwise acquired Royal Dutch/Shell securities during the Class Period, and either lost money on the transaction or still hold the securities, you may wish to join in the action to serve as lead plaintiff. In order to do so, you must meet certain requirements set forth in the applicable law and file appropriate papers no later than March 26, 2004.


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 Bernstein Liebhard & Lifshitz, LLP, or other counsel of your choice, to serve as your counsel in this action.


Bernstein Liebhard & Lifshitz, LLP has been retained as one of the law firms to represent the class. The attorneys at Bernstein Liebhard & Lifshitz, LLP have extensive experience in securities class action cases, and have played lead roles in major cases resulting in the recovery of hundreds of millions of dollars to investors. For more information about Bernstein Liebhard & Lifshitz, LLP, please visit our website at


If you would like to discuss this action or if you have any questions concerning this Notice or your rights as a potential class member or lead plaintiff, you may contact the Shareholder Relations Department at Bernstein Liebhard & Lifshitz, LLP, 10 East 40th Street, New York, New York 10016, (800) 217-1522 or (212) 779-1414 or by e-mail at



Bernstein Liebhard & Lifshitz, LLP

Shareholder Relations Department

(800) 217-1522

(212) 779-1414




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