Plaintiff's law firm issued a press release on August 8, 2018, announcing the law suit. According to the press release, the complaint charges Nielsen and certain of its officers with violations of the Securities Exchange Act of 1934. Nielsen describes itself as a leading global performance management company providing its clients with a comprehensive understanding of what consumers watch and what they buy and how those choices intersect.

The Complaint alleges that during the Class Period, Nielsen repeatedly assured investors that its measurement and analytics services continued to be viable and strong. In addition, according to the Company, because privacy was built into its business processes, the enactment of the European General Data Protection Regulation ("GDPR") would not impact its business, nor limit necessary access to large data sets provided by its partners like Facebook. Accordingly, despite business challenges in certain geographic regions, as late as June 5, 2018, Defendants stated the Company's 2018 financial outlook for revenue earnings and free cash flow of $800 million remained on track.

The Complaint alleges that Defendants' Class Period representations concerning the Company's current business and financial condition, including its forecasted financial results, were each materially false and misleading when made, because Defendants failed to disclose the following true facts that were known to Defendants or recklessly disregarded by them: (a) the Company recklessly disregarded its readiness for, and the true risks of, privacy-related regulations and policies, including the GDPR, on its current and future financial and growth prospects; (b) the Company's financial performance was far more dependent on Facebook and other third-party large data set providers than previously disclosed, and privacy policy changes affected the scope and terms of access Nielsen would have to third-party data; and (c) access to Facebook and other third-party provider data was becoming increasingly restricted for Nielsen and its clients. As a result of these material misrepresentations and omissions, Nielsen stock traded at artificially inflated prices of as high as $34.00 per share during the Class Period.