According to the Complaint, Mylan N.V. is the second largest generic drug manufacturer in the world with roughly 55 manufacturing and R&D facilities globally. Mylan’s largest U.S. manufacturing facility is located in Morgantown, West Virginia. At the start of the Class Period, the facility manufactured approximately 17 billion doses of medication every year, comprising 85% of all medicine Mylan sold in the United States in 2016.

The Complaint alleges that during the Class Period, Defendants made materially false and misleading statements and omissions, including statements regarding Mylan’s Morgantown plant, and engaged in a scheme to deceive the market. As a result, the Complaint alleges that the price of Mylan common stock was artificially inflated. Later, when Defendants’ prior misrepresentations and risks concealed by the fraudulent conduct, alleged in the Complaint, materialized and were disclosed to the market, the price of Mylan common stock fell precipitously. As a result of their acquisition of Mylan common stock during the Class Period—and Defendants’ alleged misstatements and omissions—Plaintiff and other members of the Class suffered economic loss, i.e., damages, under the federal securities laws.