According to the lawsuit, “Defendants misled investors by creating the false impression that as between three factors – competition, pandemic-related complications, and inflation – inflation alone accounted for the company’s reduced sales projections  … Alternatively, Defendants deliberately ignored the impact of [other  factors] … on sales and revenue. In either event, Defendants misled investors by providing the public with a materially flawed impression of the Company’s sales and revenue position for the remainder of 2022.”

Further, the complaint alleges that “Defendants misled investors by creating the false impression that the impact of competitors’ products, such as Omnipod 5, was minimal or less than expected. … Defendants’ forecasting processes failed to adequately account for the potential impact of the release of Omnipod 5 and the impact of that product on the Company’s revenue. Alternatively, [Defendants misled investors] regarding the impact of Omnipod 5 on revenue. Further, Defendants misled investors by creating the false impression that the factors which led to the decreased sales guidance in August … had not been adequately controlled for and were, in fact, improving. Alternatively, Defendants deliberately misled investors when stating that the second half of 2022 had been adequately predicted. In either event, Defendants misled investors by providing the public with materially flawed impression of the Company’s sales and revenue position for the remainder of 2022.”

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