According to the Complaint, GOL Linhas Areas Inteligentes S.A. purports to provide air passenger transportation services in Brazil, the rest of South America, the Caribbean, and the United States.

The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) GOL had material weaknesses in its internal controls; (2) there was substantial doubt as to the Company’s ability to continue to exist as a going concern because of negative net working capital and net capital deficiency; and (3) as a result, Defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant time.