Steve Madden Ltd.

On April 23, 2004, the Honorable John Gleeson, United States District Court Judge for the Eastern District of New York, entered an Order approving the Steve Madden Disgorgement Fund. The Order sets forth the process for the distribution of funds disgorged by Steve Madden who the SEC alleged engaged in illegal insider trading in the securities of Steve Madden Ltd. (SHOO). Specifically, the SEC alleged that Madden sold 100,000 shares of SHOO on May 31, 2000, while in possession of material non-public "bad news" that he was a target of a criminal investigation and was therefore likely to be indicted. When Madden was arrested and indicted on June 20, 2000, the NASD suspended SHOO stock from trading for two days, and its price dropped significantly.

For more information about the SEC's action, you can read Litigation Release No. 17015 (May 23, 2001).

Judge Gleeson appointed Stephanie Avakian, Esq., as Distribution Agent, to distribute approximately $850,000 collected by the SEC in a Distribution Fund. Persons eligible to�recover claims�from the Distribution Agent are those who purchased SHOO shares on May 31, 2000.� Proofs of Claim were due to the Distribution Agent by May 18, 2006.� The Distribution Agent has received Proofs of Claim from potential claimants and determined their eligibility to recover funds.

On September 10, 2007, the Distribution Agent filed her Proposed Distribution Application (PDA) with the Court, and served copies of the PDA on all claimants and the SEC.� The PDA describes the proposed distribution of the Fund, including payment of fees and expenses due to the Distribution Agent. Under the terms of the Court Order authorizing the Fund, the District Court must approve the PDA before payments can be made from the Fund. The claimants and the SEC may file written objections with the Court by September 30, 2007. If you object to the terms of the PDA, you may file a written objection with the Court by September 30, 2007, by writing to the following address:

Please reference Securities and Exchange Commission v. Steve Madden, Case No. CV-01-3311 (JG). You must also send a copy of your objection to�the Distribution Agent at this address:

If you would like more information about this matter, please contact the Distribution Agent at the address above, or contact her office at susan.schroeder@wilmerhale.com.

http://www.sec.gov/divisions/enforce/claims/stevemadden.htm