The Complaint alleges, in part, that TDS and its subsidiary, UScellular, made materially false and/or misleading statements and/or failed to disclose that: (i) Defendants had no reason to believe UScellular’s “free upgrade” promotional activity, which was tested and trialed during the second quarter of 2022, was effective at reducing UScellular’s postpaid churn rate as they represented to investors, as opposed to merely adding new postpaid subscribers, when its churn rate was actually increasing or remaining constant over most quarters in the class period; (ii) UScellular was not making progress with respect to its churn rate, as it represented to investors; (iii) UScellular was not in fact balancing its promotional activity and its profitability; (iv) due to extreme competition among postpaid carriers, UScellular did not have the flexibility to offset the costs from widespread, expensive promotions with price increases; and (v) as a result of the Companies’ decision for UScellular to continue engaging in heavy promotions to address its postpaid subscriber churn rate despite any lack of positive impact on churn rate, UScellular’s profitability substantially declined.