The Complaint alleges that, throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business, operations, and prospects. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) the Company overstated its operational efficiency and maintained a deficient cybersecurity and information technology infrastructure; (ii) as a result of the foregoing, the Company was unable to properly secure customer data, leaving it vulnerable to access by malicious third parties; (iii) the foregoing cybersecurity deficiencies also both rendered Dish's operations susceptible to widespread service outages and hindered the Company's ability to respond to such outages; and (iv) as a result, the Company's public statements were materially false and misleading at all relevant times.