According to the Complaint, Avon is a global manufacturer and marketer of beauty and related products. Avon's reportable segments are based on geographic operations in four regions: Europe, Middle East & Africa; South Latin America; North Latin America; and Asia Pacific. During 2016, Avon had sales operations in 57 countries and territories. Brazil is Avon's largest market, measured by revenue and number of sales representatives. In 2016, Brazil revenue was $1.2 billion, approximately 21% of Avon's total revenues. No other country accounts for more than 10% of Avon's total revenues.

The Complaint alleges that in order to inflate its reported revenue and representative growth metric during the Class Period, Avon engaged in an undisclosed scheme whereby it significantly loosened its credit terms in order to recruit new representatives in Brazil, its largest market. Avon did not disclose the changes to its credit terms in Brazil. Avon also failed to increase its allowance for doubtful accounts to account for the changes to its credit terms in Brazil.