The filed complaint alleges that defendants made false statements and/or concealed that: (1) certain of the Company’s senior executive officers manipulated Free Cash Flow targets as a means to maximize additional cash and stock incentive compensation applicable to executive officers pursuant to the Company’s annual incentive plans and long-term incentive plans; (2) the Company’s accounting practices and procedures, including its internal control over financial reporting, were deficient; and (3) as a result, defendants’ statements about the Company’s business, operations, and prospects lacked a reasonable basis.