According to the Complaint, Apache Corporation is an independent energy company that explores for, develops, and produces natural gas, crude oil, and natural gas liquids. The U.S. has historically represented nearly 60% of the Company's production and 70% of its estimated year-end proved reserves. At all relevant times, one of the Company's purported key "core growth areas" in the U.S. was the Permian region, a large oil-and-gas producing area in West Texas and New Mexico.

The Complaint alleges that, throughout the Class Period, Defendants made materially false and misleading statements about the Company's operations and financial health, including the viability and profitability of a purported large oil-and-gas resource play in the Permian Basin called Alpine High. Specifically, the Complaint alleges Defendants made false and misleading statements and/or failed to disclose that: (i) Apache intentionally used unrealistic assumptions regarding the amount and composition of available oil and gas in Alpine High; (ii) Apache did not have the proper infrastructure in place to safely and/or economically drill and/or transport those resources even if they existed in the amounts purported; (iii) these misleading statements and omissions artificially inflated the value of the Company's operations in the Permian Basin; and (iv) as a result, the Company's public statements were materially false and misleading at all relevant times.