The filed complaint alleges that defendants made false statements and/or concealed that: (i) the Company concealed the true extent of the supply chain problems it was experiencing while simultaneously exaggerating its ability to maintain a healthy supply chain in the face of global pressures; (ii) as a result, the Company’s projected earnings were materially misleading during the Class Period; (iii) the foregoing, once revealed, was reasonably likely to have a material negative impact on the Company’s financial condition; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times. Over the course of the Class Period, Baxter’s stock price declined by nearly 50%, eliminating billions of dollars in market capitalization.