According to the lawsuit, defendants made false and/or misleading statements regarding the Company’s business, operations, and prospects. Specifically, defendants failed to disclose to investors that:

• the Bausch + Lomb Corporation (“B+L”) spinoff would not result in two strong separate companies;
• without B+L, Bausch was left overly leveraged and without the cashflow generated by B+L;
• distribution of the B+L spinoff shares would not occur as represented;
• the above statements omitted and/or concealed the potential damages Bausch faced from the multiple hedge funds and institutional investors who “opted out” of the class action settlement in favor of pursuing individual claims (“Opt-Out Plaintiffs”); and
• the spinoff was not intended to benefit Bausch shareholders but instead designed to subvert the Opt-Out Plaintiffs’ lawsuit against the company.

No Class Has Been Certified. Until a class is certified, you are not represented by counsel unless you retain one. You may select counsel of your choice. You may also remain an absent class member and do nothing at this point. An investor’s ability to share in any potential future recovery is not dependent upon serving as lead plaintiff.

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