International Business Machines Corporation Common Stock (NYSE: IBM)
The Complaint alleges that during the Class Period, Defendants made false and misleading statements and engaged in a scheme to deceive the market and a course of conduct that artificially inflated the price of IBM securities and operated as a fraud or deceit on Class Period purchasers of IBM securities by misrepresenting the value of the Company’s business and prospects by providing artificially inflated revenue and growth figures for Strategic Imperatives Revenue, a financial metric manufactured by the Individual Defendants to enhance their annual incentive plan compensation and utilized by the investing marketplace to gauge the Company’s financial performance. The Complaint further alleges that as the scheme unraveled, the Company’s financial performance suffered and the market reacted to the news and the artificial inflation came out of the stock price and it fell precipitously.