According to the law firm press release, VimpelCom provides telecommunications services under various brand names in Italy, Russia, Ukraine, Kazakhstan, Uzbekistan, Tajikistan, Armenia, Georgia, Kyrgyzstan, Laos, Algeria, Bangladesh, and Pakistan. The Company offers voice and data services through a range of traditional and broadband mobile and fixed line technologies. The Company offers mobile telecommunications services under contract and prepaid plans for both corporate and consumer segments; value-added and call completion services; national and international roaming services; wireless Internet access; mobile financial services; and mobile bundles. It also provides fixed-line telecommunication services, such as voice, data, and Internet services to corporations, operators, and consumers.

The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business, operational and compliance policies. Specifically, Defendants made false and/or misleading statements and/or failed to disclose that: (i) VimpelCom had paid tens of millions of dollars to a company controlled by Gulnara Karimova ("Karimova"), daughter of the president of Uzbekistan; (ii) the payments to Karimova were unlawful bribes intended to secure VimpelCom's access to Uzbekistan's telecommunications market; and (iii) as a result of the foregoing, Defendants' statements about VimpelCom's business, operations, and prospects were false and misleading and/or lacked a reasonable basis.