Apple, Inc.

On January 2, 2019, after the close of the market, Apple announced that it would miss its previous quarterly revenue forecast for the first time in fifteen years and reported $84 billion revenue for first quarter 2019, compared to the expected range of $89 billion to $93 billion. The Company attributed the revenue miss to falling iPhone sales in China and to price cuts for iPhone battery replacements, which impacted iPhone sales.

On this news, Apple’s share price fell $15.73 per share or over 9% to close at $142.19 on January 3, 2019, thereby injuring investors.

The complaint filed in this class action alleges that throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operations, and prospects. Specifically, Defendants failed to disclose to investors: (1) the U.S.-China trade war had negatively impacted demand for iPhones and Apple’s pricing power in greater China; (2) due to Apple discounting the cost of replacement batteries to make up for the Company’s prior conduct of intentionally degrading the performance of the batteries in older iPhones, the rate at which Apple customers were replacing their batteries in older iPhones, rather than purchasing new iPhones, was negatively impacting Apple’s iPhone sales growth; (3) as a result of slowing demand, Apple had slashed production orders from suppliers for the new 2018 iPhone models and cut prices to reduce inventory; (4) defendants’ decision to withhold unit sales for iPhones and other hardware, which was a metric relevant to investors and their view of the Company’s financial performance, was designed to and would mask declines in unit sales of the Company’s flagship product; and (5) as a result, the Company's public statements were materially false and misleading at all relevant times.