CBS Securities Settlement
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This website has been established to provide general information related to the proposed settlement of the lawsuit referred to as Construction Laborers Pension Trust for Southern California, et al. v. CBS Corporation, et al., No. 1:18-cv-07796-VEC (the “Action”), pending before the Honorable Valerie E. Caproni in the United States District Court for the Southern District of New York (the “Court”). The capitalized terms used on this website, and not otherwise defined, shall have the same meanings ascribed to them in the Stipulation and Agreement of Settlement dated April 15, 2022 (the "Stipulation"), which can be found and downloaded by clicking on the Case Documents tab above.

The law firm of Robbins Geller Rudman & Dowd LLP represents you and other Settlement Class Members. You will not be charged for these lawyers. They will be paid from the Settlement Fund to the extent the Court approves their application for fees and expenses. If you want to be represented by your own lawyer, you may hire one at your own expense.


This is a securities class action brought by Lead Plaintiff Construction Laborers Pension Trust for Southern California ("Lead Plaintiff") against CBS Corporation n/k/a Paramount Global ("CBS" or the "Company") and Leslie Moonves ("Moonves") (collectively, "Defendants") for alleged violations of Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (“Exchange Act”).  The Action asserts claims on behalf of all Persons who purchased or otherwise acquired CBS Class B common stock during the period from November 29, 2017, through and including July 27, 2018.

Lead Plaintiff's claims in the Action are set forth in the Amended Complaint for Violations of the Federal Securites Laws, filed on February 11, 2019 (“Amended Complaint”). In general, Lead Plaintiff alleges that Defendants and former defendants Joseph R. Ianniello, Lawrence Liding, David Rhodes, David R. Andelman, Joseph A. Califino Jr., William S. Cohen, Gary L. Countryman, Charles K. Gifford, Leonard Goldberg, Bruce S. Gordon, Linda M. Griego, Robert N. Klieger, Martha L. Minow, Doug Morris and Shari Redstone (collecively, the “Former Defendants”) violated Sections 10(b) and 20(a) of the Exchange Act. More specifically, Lead Plaintiff alleges that throughout the putative class period, September 26, 2016 through December 4, 2018, inclusive, Defendants and Former Defendants made numerous materially false and misleading statements and/or failed to disclose adverse information regarding the Company’s policies and corporate governance, the importance of key personnel, including Moonves, and other statements made to news media, which caused the price of the Company’s Class B common stock to trade at artificially inflated prices, until the market learned of the false and misleading nature of the statements, and the Company’s stock price significantly declined. Defendants deny each and all of Lead Plaintiff’s allegations.

If you purchased or otherwise acquired CBS Class B common stock during the period from November 29, 2017, through and including July 27, 2018. you are a Settlement Class Member.  As set forth in the Stipulation, excluded from the Settlement Class are: (a) Defendants; (b) Former Defendants; (c) any person who served as an officer or director of CBS during the Settlement Class Period; (d) the Immediate Family Members of Moonves, the Former Defendants, and the excluded officers and directors; (e) any firm, trust, corporation, or other entity in which any excluded person or entity has, or had during the Settlement Class Period, a controlling interest; and (f) the legal representatives, parents, subsidiaries, agents, affiliates, heirs, successors-in-interest, predecessors, or assigns of any such excluded person or entity, in their capacities as such. Also excluded from the Settlement Class are those Persons who timely and validly exclude themselves from the Settlement Class. 


The proposed Settlement will create a cash settlement fund of $14,750,000 (the “Settlement Fund”), plus any interest that may accrue thereon less certain deductions.

The Settlement Fund, subject to deduction for, among other things, costs of class notice and administration and certain taxes and tax-related expenses, as well as attorneys’ fees and expenses, and the amount to Lead Plaintiff in connection with its representation of the Settlement Class, as approved by the Court, will be available for distribution to Settlement Class Members. Your recovery from this fund will depend on several factors, including the total dollar amount of claims represented by the valid Proofs of Claim and Release ("Proof of Claim") that Settlement Class Members send in, compared to the dollar amount of your claim, all as calculated under the Plan of Allocation discussed in the Notice of Pendency and Proposed Settlement of Class Action ("Notice").


Although the information on this website is intended to assist you, it does not replace the information contained in the Notice and the Stipulation. We recommend you read the Notice and other relevant case documents carefully.



The only way to be eligible to receive a payment from the Settlement. Proofs of Claim must be postmarked or submitted online on or before September 19, 2022.


Get no payment. This is the only option that potentially allows you to ever be part of any other lawsuit against the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement. Should you elect to exclude yourself from the Settlement Class you should understand that Defendants and the other Released Defendant Parties will have the right to assert any and all defenses they may have to any claims that you may seek to assert, including, without limitation, the defense that any such claims are untimely under applicable statutes of limitations and statutes of repose. Exclusions must be postmarked on or before September 19, 2022.


Write to the Court about why you do not like the Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and expenses. You will still be a Settlement Class Member. Objections must be received by the Court and counsel on or before September 19, 2022. If you submit a written objection, you may (but do not have to) attend the hearing.


Ask to speak in Court about the fairness of the Settlement. Requests to speak must be received by the Court and counsel on or before September 19, 2022.


Receive no payment. You will, however, still be a Settlement Class Member, which means that you give up your right to ever be part of any other lawsuit against the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement and you will be bound by any judgments or orders entered by the Court in the Action.


Submit Proof of Claim September 19, 2022
Request Exclusion September 19, 2022
Submit Written Objection September 19, 2022
Submit Notice of Intent to Appear September 19, 2022
Final Approval Hearing November 3, 2022, at 2:30 p.m. EST