According to the Complaint, PG&E was incorporated in California in 1995 as a holding company whose primary
operating subsidiary is Pacific Gas and Electric, a public utility operating in northern and central California. The Company generates revenues mainly through the sale and delivery of electricity and natural gas to customers.

The Complaint alleges that throughout the Class Period, Defendants made false and/or misleading statements and/or failed to disclose that (i) PG&E had failed to maintain electricity transmission and distribution networks in compliance with safety requirements and regulations promulgated under state law; (ii) consequently, PG&E was in violation of state law regulation; (iii) PG&E's electricity networks would cause numerous wildfires in California; and (iv) as a result of the foregoing, Defendants' statements about the Company's business and operations were materially false and misleading at all relevant times.