Reckitt Benckiser Group plc

On July 24, 2017, in connection with its second-quarter 2017 financial results, the Company recorded a £318 million charge related to ongoing U.S. Department of Justice (“DOJ”) and Federal Trade Commission (“FTC”) investigations into the Company’s former Reckitt Benckiser Pharmaceuticals Inc. operations, which was devoted to opioid addiction treatments.

On this news, the Company’s American depositary share price fell $1.01, or nearly 5%, to close at $20.34 on July 24, 2017, thereby injuring investors.

Then, on February 19, 2018, the Company recorded a £296 million charge as part of its full-year 2017 financial results as a result of the DOJ and FTC investigations, along with a new investigation into the Company by California Department of Insurance.

On this news, the Company’s American depositary share price fell $2.04, or over 10%, to close at $16.76 on February 19, 2018, thereby further injuring investors.

Then, on April 9, 2019, a criminal indictment was filed by the DOJ against Indivior plc (formerly Reckitt Benckiser Pharmaceuticals Inc.). The indictment detailed a long-term scheme by the Company to defraud investors and the general public through the marketing of Suboxone Film that led to more than $3 billion in illegitimate proceeds.

On this news, the Company’s American depositary share price fell $1.03, or over 6%, to close at $15.87 on April 10, 2019, thereby further 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) that defendants had engaged in a scheme to artificially inflate the sales of Suboxone Film by more than $3 billion by falsely touting the drug’s purportedly superior efficacy and safety as compared to tablets; (2) that, contrary to defendants’ public statements, the FDA and internal Company documents had concluded that Suboxone Film posed a potentially greater risk of abuse and child endangerment than other available treatments; (3) that defendants had fabricated a safety scare involving Suboxone Tablets in order to unlawfully delay and prevent generic competition; (4) that defendants had engaged in a massive marketing campaign that had misrepresented the purported benefits of Suboxone Film as compared to Suboxone Tablets to doctors, healthcare providers, government regulators and investors; (5) that defendants had encouraged Suboxone sales through medical providers that they knew were overprescribing the drug, facilitating the drug’s abuse and/or prescribing it in a careless and clinically unwarranted manner, often to hundreds of individuals at a time; (6) that, as a result of the foregoing, Reckitt’s revenues, net income and earnings were artificially inflated and the product of illicit business practices; and (7) that, as a result of the foregoing, Defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.