The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business prospects. Specifically, the Complaint alleges that Defendants' statements were materially false and misleading in that the Company kept lead generation spending flat for more than a year, did not meet its internal sales hiring goals, and knowingly allowed “chaos” to “reign” over an inexperienced and understaffed salesforce, which resulted in a severely depleted pipeline and the failure to generate revenue and profits through sales, other than through an undisclosed and deceptive unsustainable pull-in scheme.