According to the Complaint, Defendants made false and/or misleading statements and/or failed to disclose: (i) Ericsson overstated the extent to which it had reformed its business practices to eliminate the use of bribes to secure business in foreign countries; (ii) Ericsson had paid bribes to the terrorist group ISIS to gain access to certain transport routes in Iraq; (iii) accordingly, the Company’s revenues derived from its operations in Iraq were, in at least substantial part, derived from unlawful conduct and thus unsustainable; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.