The Complaint alleges that Meta and its senior executives knowingly or recklessly failed to tell investors that (1) Apple’s iOS privacy changes were having a material impact on Meta’s ability to provide the kind of targeted advertising that its customers wanted and, as a result, customer ad spending was dropping precipitously; (2) Meta’s mitigation efforts were either not properly implemented or ineffective; (3) measurement of ads was not accurate as mitigation efforts were failing; and (4) Meta did not have a plan in place to properly address the impact of the iOS privacy changes.