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

• Kohl’s Strategic Plan was not well tailored to achieving the Company’s stated goals;
• the defendants had likewise overstated the Company’s success in executing its Strategic Plan;
• Kohl’s had deficient disclosure controls and procedures, internal control over financial reporting, and corporate governance mechanisms;
• as a result, the Company’s Board was able to and did withhold material information from shareholders about the state of Kohl’s in the lead-up to the Company’s annual meeting;
• all the foregoing, once revealed, was likely to have a material negative impact on Kohl’s financial condition and reputation; and
• as a result, the Company’s public statements were materially false and misleading at all relevant times.

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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