The Complaint alleges that the Defendants made materially false or misleading statements regarding its business, operations, and financial condition during the Class Period. Specifically, the lawsuit alleges that the Company: (1) utilized an extensive discount program designed to incentivize its customers to place bulk orders in excess of procedure demand; (2) had an undisclosed discount program that artificially and unsustainably inflated the Company’s reported U.S. handpiece unit sales and revenues by pulling forward sales at the expense of future periods;  (3) caused customer handpiece orders to materially exceed underlying procedure demand throughout the Class Period and that this differential had materially grown over time; (4) had a consistent surplus of U.S. handpiece unit sales relative to performed procedures that created a glut of field inventory and overstocking amongst PROCEPT’s customer base, amounting to more than 10,000 excess units by the end of the Class Period; (5) materially overstated PROCEPT’s handpiece unit sales and the utilization of PROCEPT’s field Systems; (6) was acutely exposed to material undisclosed risks of significant operational and financial harm; and (7) was unable to achieve its stated 2025 handpiece sales and revenue guidance and such guidance lacked a reasonably achievable factual basis.