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Allegations
The filed complaint alleges that Dollar General Corporation made materially false and/or misleading statements and/or failed to disclose that: (a) Dollar General stores were chronically understaffed and suffering from logistical and inventory management problems that left stores with tens of millions of dollars’ worth of outdated and unwanted inventory, mispriced goods, and lost and damaged items; (b) large backlogs of unsellable merchandise had built up at Dollar General’s stores, which inventory had not been timely written down due to understaffing and the Company’s failure to manage its inventory; (c) the allotment of employee hours per store per week imposed by Dollar General management placed employees in virtually impossible situations where assigned tasks, including those necessary for effective store operations, could not be completed within the allotted time; (d) in violation of state laws, including state law violations identified by state regulators in Arizona, Louisiana, Mississippi, Missouri, North Carolina, and Ohio, Dollar General was systematically overcharging customers for items upon checkout; (e) Dollar General’s reported revenue and earnings during the class period were artificially inflated by defendants’ over-pricing scheme; (f) Dollar General’s failure to manage store inventories and accurately price items upon checkout risked the loss of customers, lower sales, adverse regulatory actions, and reputational fallout; (g) Dollar General was not on track to achieve the 4Q22 guidance provided to investors of 6% to 7% same-store sales growth or quarterly diluted EPS of $3.15 to $3.30 and was running more than one hundred million dollars behind the Company’s annual net sales guidance of 11% growth; and (h) as a result of (a)-(g) above, defendants’ statements about Dollar General’s business metrics, operations, and financial prospects were materially false and misleading and/or lacked a reasonable factual basis when made.