According to the Complaint, The Kraft Heinz Company was created through a merger between Heinz and Kraft on July 2, 2015 and began trading publicly on July 6, 2015. Following the Merger, Kraft Heinz was the third largest food and beverage manufacturer in North America and the fifth largest globally with more than $28 billion in global
sales, and the steward of numerous iconic brands, including Heinz ketchup, Oscar Mayer meats, Kraft cheese products, Maxwell House coffee, Jell-O desserts, and Philadelphia cream cheese. During the Class Period, Kraft Heinz derived the vast majority of its revenue from sales in the United States and Canada.

The Complaint alleges that throughout the Class Period, Defendants: (a) employed devices, schemes, and artifices to defraud; (b) made untrue statements of material facts or omitted to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and/or (c) engaged in acts, practices, and a course of business that operated as a fraud or deceit upon Plaintiff and others similarly situated in connection with their purchases of Kraft Heinz common stock and options during the Class Period. Specifically, the Complaint alleges those statements included, but were not limited to: misleading statements concealing that Kraft Heinz’s cost-cutting measures had severely impaired the Company’s supply chain and brand value; misleading statements concealing that Kraft Heinz’s cost reductions were not synergistic, efficiency-generating, or sustainable, but were instead brute force cost cuts that impaired core business functions; misleading statements purporting to accurately report Kraft Heinz’s financial results; misleading statements reassuring investors about the integrity of Kraft Heinz’s internal controls and the robustness of its goodwill impairment testing.