The filed complaint alleges that defendants made false statements and/or concealed that: (a) GrafTech’s manufacturing operations in Monterrey, Mexico had for decades chronically contaminated neighboring communities with harmful carcinogenic gasses and particulate matter; (b) GrafTech had signed agreements with local authorities committing itself to improving the environmental performance of its Monterrey facility, but repeatedly failed to honor these commitments; (c) GrafTech had been repeatedly warned over an approximately 30-year period regarding its wanton disregard for the environment and health and well-being of people near its operations in Monterrey, Mexico; (d) GrafTech’s operations in Monterrey, Mexico were not in compliance with applicable environmental laws and regulations; (e) the Company had failed to adequately remediate the environmental problems caused by the Monterrey facility following the 2019 administrative proceeding conducted by the Department of Sustainable Development of the State of Nuevo León; (f) the government of Apodaca had sought intervention from the State of Nuevo León authorities to curtail and prevent the adverse environmental impacts and noncompliance with environmental laws and regulations caused by the Monterrey facility; (g) GrafTech’s purported cost leadership was achieved in substantial part by failing to implement appropriate and effective environmental safeguards at its manufacturing facility in Monterrey, Mexico; (h) GrafTech’s capital expenditures and/or related operational projects were woefully insufficient to adequately address the harm that the Company’s operations in Monterrey, Mexico had inflicted on the environment and people within the neighboring communities; (i) as a result of (a)-(h), GrafTech was acutely exposed to undisclosed material risks that the Company’s manufacturing operations in Monterrey, Mexico would be severely disrupted by government action or enforcement; and (j) as a result of (a)-(i), GrafTech was acutely exposed to undisclosed material risks that its supplies of pin stock and graphite electrodes would be withdrawn and/or materially diminished, thereby materially harming the Company’s business, operations, reputation, and financial results.