According to the Complaint, Evolus, Inc. is a medical aesthetic company formed with the sole aim to develop and introduce a cheaper alternative to Botox® to the U.S. market.

The Complaint alleges that Evolus made false and misleading statements to the public throughout the Class Period and failed to disclose that: (1) the real source of botulinum toxin bacterial strain as well as the manufacturing processes used to develop Jeuveau™ originated with and were misappropriated from Medytox; (2) sufficient evidentiary support existed for the allegations that Evolus misappropriated certain trade secrets relating to the botulin toxin strain and the manufacturing processes for the development of Jeuveau™; (3) as a result, Evolus faced a real threat of regulatory and/or court action, prohibiting the import, marketing, and sale of Jeuveau™; (4) which in turn seriously threatened Evolus’ ability to commercialize Jeuveau™ in the United States and generate revenue; and (5) any revenues generated from the sale of Jeuveau™ were based on Evolus’ unlawful activities, including the misappropriation of trade secrets and secret manufacturing processes belonging to Allergan and Medytox.