The Complaint alleges that Defendants made materially false and misleading statements during the Class Period regarding the Company's business and financial prospects. Specifically, the Complaint alleges that Defendants made false and/or misleading statements and/or failed to disclose that: (1) the well spacing at Dominator was aggressive and highly risky, and premised on no reasonable basis to believe it would work as intended; (2) Concho's practice of implementing tighter well spacing was not relegated to a handful of "tests" and therefore more widespread than the market was led to believe; (3) it was known or recklessly disregarded that any measures to mitigate well spacing risks were non-existent and or/impossible; (4) these risks had manifested during the Class Period, causing underground well interference and permanently decreasing production, forcing the Company to scale back production targets and adopt more conservative spacing measures in its other projects; (5) it would take multiple quarters to unwind the impacts of the widespread well spacing failure; and (6) as a result, the Company's public statements were materially false and misleading at all relevant times.