Great Wolf Shareholders Continue to Retain Scott + Scott, LLC: The First Firm Retained and Filed in This Case

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Expanded allegations to complaint show Great Wolf to be an alleged IPO dog.

) on December 8, 2005, filed an expanded securities fraud and negligence class action complaint in the United States District Court for the Western District of Wisconsin (05-C-0687-C) against Great Wolf Resorts Inc. (

Scott+Scott, LLC, which filed the initial lawsuit against Great Wolf Resorts, Inc. (“Wolf” or Company”) on December 8, 2005, filed an expanded securities fraud and negligence class action complaint in the United States District Court for the Western District of Wisconsin (05-C-0687-C) against Great Wolf Resorts Inc. ("Great Wolf" or the "Company"). This updated complaint with additional facts shows the teeth of our filing client, a non-profit charitable foundation: the offering took the Wolf stock to just over $25.00 a share and then it plunged $13.65. Scott + Scott's new complaint, which has been given credence by analysts in the field, adds parties including underwriters of the December 2004 Initial Public Offering (“IPO”): Citigroup Global Markets, Inc., A.G. Edwards & Sons Inc., Raymond James & Associates Inc., Calyon Securities (USA), Societe Generale, ThinkEquity Partners, LLC, and auditors Rubin, Brown, Gornstein & Co., LLP, and Deloitte and Touche. The complaint seeks to represent all of those investors who purchased or acquired Great Wolf securities between December 14, 2004, and July 28, 2005, inclusive (the "Class Period"), but any purchaser of Great Wolf securities may contact the firm as this class period can change as information is revealed. You can contact attorney Neil Rothstein directly at 619-251-0887.

The Company is headquartered in Madison, Wisconsin. Scott+Scott's complaint, seen at, alleges that defendants' registration statements issued in connection with the Company's 2004 Initial Public Offering ("IPO") contained untrue statements of material fact. According to the complaint, the Company provided misleading, unreliable and unpredictable quarterly and annualized guidance based on its preferred non-GAAP EBITDA measure that stands for "earnings before interest, taxes, depreciation, and amortization" and is a measure of cash flow. Since defendants' EBITDA number was allegedly unreliable, both the Company's business prospects and in fact the value of the underlying business was in doubt because the value of the Company was based on a defective valuation measure. It is alleged that the Company used this defective measure to convince investors to buy the Company's stock during the IPO. On July 28, 2005, the Company's stock price sank as investors' learned the true magnitude of the Company's earnings shortfall and its cause. Analysts concluded that defendants were fully aware of the true magnitude of the earnings miss when they were out marketing clients at the end of June but failed to publicly disclose the materiality of the problem at that time. On the news of July 28, 2005, the price of the Company's stock plunged $6.12 to $13.65, on extremely heavy volume. The price has continued to decline since July and today trades at $10.31.

Scott+Scott, LLC, has significant experience in prosecuting investor class actions. The firm dedicates itself to client communication and satisfaction and currently is litigating major securities, antitrust and employee retirement plan actions throughout the United States. The firm represents pension funds, charities, foundations, individuals and other entities worldwide. Cases currently being litigated and/or investigated by Scott+Scott, LLC include: Mills Corporation; Diebold Inc; SFBC International; MGI Pharmacy; Halliburton; Faro Technologies, Stone Energy; Affymetrix, and Universal American Financial, among others. Its success has brought shareholders hundreds of millions of dollars in cases against Mattel, Royal Dutch/Shell, Sprint, ImClone, Emulex and others.

If you wish to discuss this action or have questions concerning this notice or your rights as a class member, please contact Scott+Scott for more information. Scott+Scott will provide class members with case materials, answer all questions regarding participation and rights and assist with other services the firm provides. There is no cost or fee to you. Contact Scott+Scott partners Neil Rothstein (800-332-2259, ext. 22 or cell 619-251-0887 or David R. Scott (800-404-7770). Institutional Investors may also contact the firm.

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