Tal Education Group Loss Submission Form

(a) TAL’s revenue and operational growth was the result of deceptive marketing tactics and illicit business practices that flouted Chinese laws, regulations and policies, and exposed the Company to an extreme risk that more draconian measures would be imposed on the Company; (b) TAL had engaged in misleading and fraudulent advertising practices, including the provision of false and misleading discount information designed to obfuscate the true cost of the Company’s programs to its customers, the creation of fake customer reviews designed to fraudulently lure new customers to TAL programs, the misrepresentation of teacher qualifications and course qualities, and the marketing of rigged promotional events; (c) TAL had defied Chinese policies designed to alleviate the burden imposed by tutoring services on students and their families, including by imposing hefty advances and recurring debt payments on course enrollees, by offering courses designed to give affluent students unfair advantages, by holding courses outside of allowable tutoring hours, and by linking for-profit courses to government-mandated schooling; (d) as a result of the foregoing, TAL was subject to an extreme undisclosed risk of adverse enforcement actions, regulatory fines and penalties, and the imposition of new rules and regulations adverse to the Company’s business and financial interests; and (e) as a result of the foregoing, TAL’s historical growth was not sustainable or the result of legitimate business tactics as represented, and defendants’ positive statements about the Company’s business, operations, and prospects were materially false and misleading and lacked a reasonable factual basis.