According to the Complaint, Anaplan Inc. is a software company that provides a cloud-based connected planning platform to connect organizations and people. One of the most important financial metrics for investors in analyzing Anaplan’s performance is “calculated billings.” The Company defines calculated billings as revenue plus the sequential change in total deferred revenue as presented on the balance sheet. Calculated billings are used by investors to evaluate subscription businesses, such as Anaplan, that do not directly disclose billings as a part of their financial reporting.

The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose to investors that: (1) the Company was undergoing sales organization and execution challenges; (2) these organizational challenges were causing the Company to miss on closing very important large deals; and (3) as a result, Anaplan’s financial guidance for “calculated billings growth” was baseless and unattainable. The Complaint further alleges that, while in possession of this material non-public information, Anaplan insiders dumped approximately $30 million worth of Anaplan stock at artificially inflated prices.