B. Parmalat Finanziaria’s Bond Offerings in the United States
17. Between October 1997 and December 2003, while the fraud described above was
ongoing, Parmalat Finanziaria sold over $1 billion in bonds to United States insurance
companies in private placements that were exempt from registration with the Commission. Each
offering’s materials included a detailed Private Placement Memorandum (“PPM”) and the
audited consolidated financial statements of Parmalat S.p.A. On occasion the PPMs also
included financial data from Parmalat Finanziaria. Given the magnitude of Parmalat S.p.A.’s
contribution to Parmalat Finanziaria’s consolidated financial statements (approximately 70
percent of reported sales) and that the majority of the fraudulent conduct was reflected in the