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According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts related to the demand for Krispy Kreme products at McDonald’s locations. Specifically, defendants failed to disclose that lower demand at McDonald’s locations accounted for the declining average weekly sales per store; the partnership with McDonald’s was not profitable thereby causing Krispy Kreme to pause expansion into new McDonald’s locations. The truth began to emerge on February 25, 2025, when Krispy Kreme issued a press release reporting disappointing fourth quarter 2024 financial results despite the recent partnership with McDonald’s restaurants in March 2024. The Company reported a decline in “net revenue of $404 million, a decline of 10.4%” in addition to a decrease in “DFD average sales per door per week…driven by changing customer mix.” On this news, Krispy Kreme’s stock price declined from $9.13 per share on February 24, 2025 to $7.13 per share on February 25, 2025. On May 8, 2025, defendants issued a press release announcing the Company’s first quarter 2025 financial results. Defendants reported “[n]et revenue was $375.2 million in the first quarter of 2025, a decline of 15.3% or $67.5 million.” Further, the Company announced it is “reassessing the deployment schedule together with McDonald’s while it works to achieve a profitable business model for all parties” and given “the uncertainty around the McDonald’s deployment schedule, the Company is withdrawing its prior full year outlook and not updating it at this time.” On this news, the price of Krispy Kreme’s common stock declined from a closing market price of $4.33 per share on May 7, 2025 to $3.26 per share on May 8, 2025, a decline of about 25% in the span of just a single day.

(a) DoubleVerify’s customers were shifting their ad spending from open exchanges to closed platforms, where the Company’s technological capabilities were limited and competed directly with native tools provided by platforms like Meta Platforms and Amazon; (b) DoubleVerify’s ability to monetize on its Activation Services was limited because the development of its technology for closed platforms was significantly more expensive and time-consuming than disclosed to investors; (c) DoubleVerify’s Activation Services in connection with certain closed platforms would take several years to monetize; (d) DoubleVerify’s competitors were better positioned to incorporate AI into their offerings on closed platforms, which impaired DoubleVerify’s ability to compete effectively and adversely impacted the Company’s profits; (e) DoubleVerify systematically overbilled its customers for ad impressions served to declared bots operating out of known data center server farms; (f) DoubleVerify’s risk disclosures were materially false and misleading because they characterized adverse facts that had already materialized as mere possibilities; and (g) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially false and/or misleading or lacked a reasonable basis.

(i) the Salt Lake City Facility’s production capacity, and defendants’ progress in developing the same, was overstated; (ii) the overall value of the U.S. Army’s Short Range Reconnaissance Program of Record Tranche 2 contract was overstated; and (iii) as a result, defendants’ public statements were materially false and misleading at all relevant times.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of Organon’s priorities, particularly, related to capital allocation through quarterly dividends. Notably, defendants concealed the high priority of Organon’s debt reduction strategy following the Company’s acquisition of Dermavant, resulting in a 70% decrease for the regular quarterly dividend. Following this news, the price of Organon’s common stock declined dramatically. From a closing market price of $12.93 per share on April 30, 2025, Organon’s stock price fell to $9.45 per share on May 1, 2025, a decline of more than 27% in the span of just a single day.

(i) Fortrea overestimated the amount of revenue the long-term projects in its portfolio, the Pre-Spin Projects, were likely to contribute to the Company’s 2025 earnings; (ii) Fortrea overstated the cost savings it would likely achieve by exiting the transition services agreements; (iii) as a result, the Company’s previously announced EBITDA targets for 2025 were inflated; (iv) accordingly, the viability of the Company’s post-spin-off business model, as well as its business and/or financial prospects, were overstated; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(1) preterm infants were at an increased risk of developing NEC by consuming Reckitt’s cow’s milk-based formula, Enfamil; (2) of the attendant impact on Reckitt’s sales of Enfamil and Reckitt’s exposure to legal claims; and (3) as a result of the above, defendants’ positive statements about the Company’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(i) the Company’s lead product candidate, PGN-EDO51, was less effective and safe than defendants had led investors to believe; (ii) phase two, CONNECT2 study was dangerous or otherwise deficient for purposes of U.S. Food and Drug Administration (“FDA”) approval; (iii) as a result of all the foregoing, PepGen was likely to halt the CONNECT2 study, and PGN-EDO51’s clinical, regulatory, and commercial prospects were overstated; and (iv) as a result, defendants’ public statements were materially false and misleading at all relevant times.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of Vestis’ ability to grow its business; notably that Vestis would be unable to execute on planned strategic initiatives to drive purported improvements to the customer experience and its onboarding efforts in order to drive new customer growth, increased customer retention, and increased revenue from existing customers. On May 7, 2025, Vestis announced its financial results for the second quarter of fiscal 2025, withdrew its revenue and growth guidance for the full fiscal year 2025, and provided guidance for the third quarter of fiscal 2025 that fell significantly below market expectations. The Company attributed its poor results partially to “lost business in excess of new business,” but primarily on “lower adds over stops, which is how we describe volume changes with our existing customers.” The Company attributed its decision to pull full-year guidance and provide disappointing third quarter targets to the “increasingly uncertain macro environment.” Following this news, the price of Vestis’ common stock declined dramatically. From a closing market price of $8.71 per share on May 6, 2025, Vestis’ stock price fell to $5.44 per share on May 7, 2025, a decline of about 37.54% in the span of just a single day.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of RP-A501’s safety and clinical trial protocol; notably, that Rocket knew Serious Adverse Events (SAEs), including death of participants enrolled in the study, were a risk. In particular, Rocket amended the trial’s protocol to introduce a novel immunomodulatory agent to the pretreatment regimen without providing this critical update to shareholders. Such statements absent these material facts caused Plaintiff and other shareholders to purchase Rocket’s securities at artificially inflated prices. On May 27, 2025, Rocket announced that the FDA placed a clinical hold on the RP-A501 Phase 2 pivotal study after at least one patient suffered a Serious Adverse Event (SAE), ultimately, death, while enrolled in the study following a substantive amendment to the protocol that the Company failed to disclose to investors at the time management made the revision. In fact, Rocket stated that, while the patient was dosed in May, the decision to amend the protocol was made “several months” earlier. Despite this, Rocket made no attempt to alert investors or the public to the change until after the SAE occurred. Following this news, the price of Rocket’s common stock declined dramatically. From a closing market price of $6.27 per share on May 23, 2025, Rocket’s stock price fell to $2.33 per share on May 27, 2025, a decline of about 37% in the span of just a single trading day.

(i) 3D Systems had understated the impact of weakened customer spending on the Company’s business, while overstating its resilience in challenging industry conditions; (ii) in addition, the updated milestone criteria in the partnership with United Therapeutics Corporation would negatively impact the Company’s regenerative medicine program revenue; and (iii) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(i) changes in Google Search’s algorithm and features like AI Overview were causing users to stop their query on Google Search; (ii) these algorithm changes were materially different than prior instances of reduced traffic to the Reddit website; (iii) defendants were aware that the increase in the query term “Reddit” on search engines was because users were getting the sought after answer from Google Search without having to go to Reddit, and not because they intended to visit Reddit; (iv) this zero-click search reality was dramatically reducing traffic to Reddit in a manner the Company was unable to overcome in the short term; (v) defendants, therefore, lacked a reasonable basis for their outlook on user rates and advertising revenues; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(i) Apple misstated the time it would take to integrate the advanced AI-based Siri features into its devices; (ii) accordingly, it was highly unlikely that these features would be available for the iPhone 16; (iii) the lack of such advanced AI-based features would hurt iPhone 16 sales; (iv) as a result, Apple’s business and/or financial prospects were overstated; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(i) ELEVIDYS, a prescription gene therapy for Duchenne, posed significant safety risks to patients; (ii) ELEVIDYS trial regimes and protocols failed to detect severe side effects; (iii) the severity of adverse events from ELEVIDYS treatment would cause the Company to halt recruitment and dosing in ELEVIDYS trials, attract regulatory scrutiny, and create greater risk around the therapy’s present and expanded approvals; and (iv) as a result of the foregoing, defendants materially misled with, and/or lacked a reasonable basis for, their positive statements.

(1) Hims was engaged in the “deceptive promotion and selling of illegitimate, knockoff versions of Wegovy® that put patient safety at risk;” (2) as a result, there was a substantial risk that the Company’s collaboration with Novo Nordisk would be terminated; and (3) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

(i) Petco’s pandemic-related tailwinds were unsustainable, as was its business model of selling primarily premium and/or high-grade pet food; (ii) accordingly, the strength of Petco’s differentiated product strategy was overstated; (iii) defendants downplayed the true scope and severity of the foregoing issues, the magnitude of changes needed to rectify those issues, and the likely negative impacts of their mitigation strategy on Petco’s comparable sales metric; (iv) accordingly, defendants overstated Petco’s ability to deliver sustainable, profitable growth; and (v) as a result, defendants’ public statements were materially false and misleading at all relevant times.

(i) iRobot overstated the extent to which the restructuring plan would help the Company maintain stability after the termination of the Amazon acquisition; (ii) as a result, it was unlikely that iRobot would be able to profitably operate as a standalone company; (iii) accordingly, there was substantial doubt about the Company’s ability to continue as a going concern; and (iv) as a result, defendants’ public statements were materially false and misleading at all relevant times.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of Centene’s enrollment and morbidity rates. Investors began to question the veracity of defendants’ public statements on July 1, 2025, when Centene issued a press release withdrawing 2025 guidance. Particularly, following an analysis of the 2025 Health Insurance Marketplace, Centene’s overall market growth across 22 states, or 72% of the Company’s marketplace membership, was lower than expected. In pertinent part, the Company stated that this preliminary analysis resulted in a reduction of its previously issued guidance to approximately $1.8 billion or an adjusted diluted EPS of $2.75. Following this news, Centene’s common stock declined dramatically, from a closing market price of $56.65 per share on July 1, 2025, Centene’s stock price fell to $33.78 per share on July 2, 2025, a decline of 40.4%.

(i) XPLR was struggling to maintain its operations as a yieldco; (ii) defendants temporarily relieved this issue by entering into certain financing arrangements, described herein, while downplaying the attendant risks; (iii) XPLR could not resolve those financings before their maturity date without risking significant unitholder dilution; (iv) as a result, defendants planned to halt cash distributions to investors and instead redirect those funds to, inter alia, resolve those financings; (v) as a result of all the foregoing, XPLR’s yieldco business model and distribution growth rate was unsustainable; and (vi) as a result, defendants’ public statements were materially false and misleading at all relevant times.

American Outdoor issued a press release on June 26, 2025, reporting its financial results for its fourth quarter and full fiscal year 2025. Among other items, American Outdoor disclosed that retailers accelerated orders in the final weeks of the quarter, effectively pulling forward an estimated $8 million to $10 million in sales from the upcoming fiscal year. American Outdoor also announced its decision to suspend its fiscal 2026 guidance, citing uncertainties around tariffs. Following this news, American Outdoor's stock price fell over 13% on June 27, 2025.