The filed complaint alleges that defendants made false statements and/or concealed that: (i) Icahn Enterprises was inflating its net asset value; (ii) the Company was using money taken in from new investors to pay out dividends to old investors; (iii) as a result, the Company would become the subject of criminal and/or regulatory scrutiny; and (iv) as a result of the foregoing, Defendant’s positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.