Inogen, Inc.

On February 26, 2019, Inogen issued a press release announcing its fourth quarter and fiscal year 2018 financial and operating results and held a conference call with investors and analysts to discuss its business metrics and financial prospects. During the call, the Company's Chief Executive Officer backtracked on Inogen's prior total addressable market (“TAM”) estimate of 2.5 to 3 million patients, and blamed Inogen's poor "domestic business-to-business sales" on "order activity [that] slow[ed] from one national home care provider in the fourth quarter of 2018." Inogen also reported that its non-GAAP EBITDA for the quarter was $10.5 million, 9.5% lower than in fiscal 2017, and significantly reduced its previously provided 2019 net income guidance, citing in large part the decline in its own stock price.

On this news, shares of Inogen fell $33.77 per share, or more than 24%, to close at $106.28 per share on February 27, 2019, thereby injuring investors.

The complaint filed in this class action alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding Inogen’s business, operational and compliance policies. Specifically, Defendants made false and/or misleading statements and/or failed to disclose that: (i) Inogen was overstating the true size of the total addressable market (“TAM”) for its portable oxygen concentrators, claiming it was upwards of 3 million people; (ii) Inogen was misstating the basis for its calculation of the TAM; (iii) Inogen was falsely attributing its sales growth to the strong sales acumen of its salesforce, when in reality it was due in large part to sales tactics designed to deceive its elderly customer base (including inducing them to purchase portable oxygen concentrators from Inogen at inflated prices by claiming that Medicare did not otherwise cover payment for such devices if obtained from other providers); (iv) as such, the growth in Inogen’s domestic business-to-business sales to home medical equipment (“HME”) providers was inflated, unsustainable and was eroding direct-to-consumer sales; (v) very little of Inogen’s business was actually coming from the more stable Medicare market; and (vi) as a result, Inogen’s public statements were materially false and misleading at all relevant times.