According to the Complaint, Baidu, Inc. is a technology company specializing in Internet-related services and products and artificial intelligence. The Baidu search engine is the second largest search engine in the world and the most widely used search engine in China, with a market share of more than 70%. The Company also provides a portfolio of apps that provide mobile device access to the Company’s search and feed services, along with social media services and both user generated and professionally produced media content.

The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company’s business, operational and compliance policies. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) Baidu’s feed services were not in compliance with applicable Chinese regulatory standards; (ii) the foregoing noncompliance subjected the Company to a heightened risk of regulatory enforcement, including the removal or suspension of certain of Baidu’s services and products; (iii) accordingly, the Company’s revenues derived from online marketing services were unlikely to be sustainable; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.