According to the Complaint, Apple is a multinational technology company headquartered in Cupertino, California that designs, develops, and sells consumer electronics, computer software, and online services. The Company's most well-known products include its iconic iPhone smartphones, the iPad tablet computer, the Mac personal computer, the iPod portable media player, the Apple Watch smartwatch, the Apple TV digital media player, and the HomePod smart speaker.

The Complaint alleges that during the Class Period, Defendants made materially false and misleading statements and/or failed to disclose adverse information regarding Apple's business and prospects. Specifically, the Complaint alleges Defendants failed to disclose that: (a) the U.S.-China trade war had negatively impacted demand for iPhones and Apple's pricing power in greater China; (b) due to Apple discounting the cost of replacement batteries to make up for the Company's prior conduct of intentionally degrading the performance of the batteries in older iPhones, the rate at which Apple customers were replacing their batteries in older iPhones, rather than purchasing new iPhones, was negatively impacting Apple's iPhone sales growth; (c) as a result of slowing demand, Apple had slashed production orders from suppliers for the new 2018 iPhone models and cut prices to reduce inventory; and (d) Defendants' decision to withhold unit sales for iPhones and other hardware, which was a metric relevant to investors and their view of the Company's financial performance, was designed to and would mask declines in unit sales of the Company's flagship product.