According to the Complaint, Brookdale Senior Living Inc. is the nation’s largest senior-living community operator. As of February 1, 2020, Brookdale owned 356 communities, leased 307 communities, managed seventy-seven communities on behalf of third parties, and three communities for which it has an equity interest. The Company operates independent living, assisted living and dementia-care communities and CCRCs. Through its ancillary services programs, the Company also offers a range of outpatient therapy, home health, personalized living and hospice services.

The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company’s business, operational, and compliance policies. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) Brookdale’s financial performance was sustained by, among other things, the Company’s purposeful understaffing of its senior living communities; (ii) the foregoing conduct subjected Brookdale to an increased risk of litigation and, once revealed, was foreseeably likely to have a material negative impact on the Company’s financial results and reputation; (iii) as a result, the Company’s financial results were unsustainable; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.