Telephone and Data Systems, Inc.

On November 4, 2022, TDS released its third quarter 2022 financial results, reporting that UScellular’s heavy promotional activity, including a free phone upgrade promotion, had failed to correct the Company’s postpaid churn rate and had substantially eroded the Company’s profitability.

On this news, TDS’s stock price fell $4.29, or 25.9%, to close at $12.28 per share on November 4, 2022, 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 that: (1) Defendants had no reason to believe UScellular's "free upgrade" promotional activity, which was tested and trialed during the second quarter of 2022, was effective at reducing the UScellular's postpaid churn rate as they represented to investors, as opposed to merely adding new postpaid subscribers, when its churn rate was actually increasing or remaining constant over most quarters in the class period; (2) UScellular was not making progress with respect to its churn rate, as it represented to investors; (3) UScellular was not in fact balancing its promotional activity and its profitability; (4) due to extreme competition among postpaid carriers, UScellular did not have the flexibility to offset the costs from widespread, expensive promotions with price increases; (5) as a result of the Companies' decision for UScellular to continue engaging in heavy promotions to address its postpaid subscriber churn rate despite any lack of positive impact on churn rate, UScellular's profitability substantially declined; and (6) as a result, Defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis at all relevant times.