According to the filed complaint, defendants made false statements and/or concealed that defendants knew that the refresh cycle would never be as lucrative as they represented, nor could it, because it consisted of old products that were a “small percentage” of the Company’s business. Moreover, defendants misrepresented and concealed that they did not have a clear picture of the true number of FortiGate firewalls that could be upgraded. And while telling investors that the refresh would gain momentum over the course of two years, Fortinet misrepresented and concealed that it had aggressively pushed through roughly half of the refresh in a period of months, by the end of 2Q 2025.