During the Class Period, defendants made false and/or misleading statements and/or failed to disclose that:

• the Company’s Precision Scheduled Railroading (“PSR”), including its use of longer, heavier trains staffed by fewer personnel, had led to the Company suffering increased train derailments and a materially increased risk of future derailments;
• the Company’s PSR, including its use of longer, heavier trains staffed by fewer personnel, was part of a culture of increased risk-taking at the expense of reasonable safety precautions due to the Company’s near-term focus solely on profits;
• the Company’s PSR, including its use of longer, heavier trains staffed by fewer personnel, rendered the Company more vulnerable to train derailments and train derailments with potentially more severe human, financial, legal, and environmental consequences;
• the Company’s capital spending and replacement programs were designed to prioritize profits over the Company’s ability to provide safe, efficient, and reliable rail transportation services;
• the Company’s lobbying efforts had undermined the Company’s ability to provide safe, efficient, and reliable rail transportation services;
• the Company’s commitment to reducing operating expenses as part of its PSR goals undermined worker safety and the Company’s purported “commitment to an injury free
  workplace” because the Company’s PSR plan prioritized reducing expenses through fewer
  personnel, longer trains, and less spending on safety training, technology, and equipment such as hot bearing wayside detectors (a/k/a “hotboxes”) and acoustic sensors;
• the Company’s rail services were, as a result of its adoption of PSR principles, more susceptible to accidents that could cause serious economic and bodily harm to the Company, the Company’s workers, the Company’s customers, third parties, and the environment;
• the Company had failed to put in place responsive practices and procedures to minimize the threat to communities in the event that these communities suffered the derailment of a Norfolk Southern train carrying hazardous and toxic materials; and
• as a result, defendants’ Class Period statements detailed above regarding the safety of Norfolk Southern’s operations were materially false and/or misleading.

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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