According to the Complaint, VMware, Inc. provides software in the areas of hybrid cloud, multi-cloud, modern applications, networking and security, and digital workspaces in the United States and internationally, and sells
its products through distributors, resellers, system vendors, and systems integrators.

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, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) VMware’s reporting with respect to its backlog of unfilled orders was not in compliance with all relevant accounting and disclosure requirements; (ii) the foregoing subjected the Company to a foreseeable risk of heightened regulatory scrutiny and/or investigation; and (iii) as a result, the Company’s public statements were materially false and misleading at all relevant times.