Also on February 21, 2012, Landesbank Baden-Wurttemberg ("LBBW") filed a summons with notice in New York state court against the Royal Bank of Scotland and certain of its affiliates in connection with its alleged purchase of one RMBS certificate for $71 million face value of RMBS in 2006.  LBBW alleges that the defendants made material misrepresentations and omissions in their RMBS Offering Materials regarding the underwriting standards used in connection with the underlying mortgage loans, the validity of the assignments of the loans to the Trusts, the nature of the underlying loans (such as LTV ratios and owner-occupancy rates), and the credit ratings assigned to the securities.  LBBW asserts claims for common-law fraud, fraudulent inducement, negligent misrepresentation, aiding and abetting fraud, and various contract claims. LBBW is seeking approximately $71 million in damages plus accrued interest and punitive damages.  Summons. 

Both the Sealink action and the LBBW action were brought by Labaton Sucharow, and the summaries of the allegations in the respective summonses with notice are substantially similar.