According to the Complaint, Bayerische Motoren Werke Aktiengesellschaft ("BMW" or the "Company"), together with its subsidiaries, purports to develop, manufacture, and sell automobiles and motorcycles, and spare parts and accessories worldwide.

The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) BMW kept a "bank" of retail vehicle sales that it used to meet internal monthly sales targets regardless of when the sales actually occurred; (2) BMW artificially manipulated sales figures by having dealers register cars as sold when the cars were still in inventory; (3) as a result, BMW's key operating metrics were inaccurate and misleading; and (4) as a result, Defendants' statements about BMW's business, operations, and prospects were materially false and/or misleading and/or lacked a reasonable basis at all relevant times.