According to the filed complaint, defendants made false statements and/or concealed that UnitedHealth never established proper firewalls between it's complementary businesses, Optum and UnitedHealthcare, as required by its own policy and as it told the court in an antitrust action, the United States Department of Justice, and investors it would do. Firewalls were never properly created for certain business applications. Despite assurances to the contrary, there was never a meaningful technological separation between Optum and UnitedHealthcare that prevented the sharing of customer sensitive information.