对具有代表性的部分国家和地区的股东团体诉讼的提起模式进行了比较分析,针对我国现状进行思考,认为由政府主导设立专门的投资人保护机构代为起诉和投资人自行起诉的二元体制比较适合我国现状,作为股东团体诉讼成熟前的过渡阶段,将有助益于鼓励诉讼的提起和股东利益的保护。 A comparative analysis is made on the mode of filing a lawsuit by shareholder groups in some representative countries and regions. According to the current situation in our country, it is considered that the government-led special investor protection agency has compared the dual system of prosecution and investor self-prosecution Suitable for the current situation in our country. As a transitional period before the litigation of shareholders 'groups is mature, it will be helpful to encourage the filing of litigation and the protection of shareholders' interests.