The filed complaint alleges that defendants made false statements and/or concealed that: (1) the Company's Bristol, Pennsylvania plant had a troubled safety record while under prior ownership and continued to be unsafe after the Company acquired it; (2) defendants did not sufficiently disclose specific risks related to conducting operations at that plant; (3) operating a chemical plant with an unsafe history and presently unsafe operations exposed the Company to a heightened risk of a chemical spill or other adverse events; and (4) as a result, defendants statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all times.