According to the law firm press release, the complaint alleges that Spectrum misrepresented and failed to disclose that: (i) Spectrum had been self-inflicting the operational issues at its Ohio and Kansas facilities; (ii) these operational issues were, in fact, recurring in nature; (iii) these operational issues would continuously impact production, shipping levels and sales; and (iv) as a result of the foregoing, the Company's financial statements were materially false and misleading at all relevant times.
According to the Complaint, Health Insurance Innovations, Inc. ("HIIQ" or the "Company") purports to distribute individual and family health insurance plans, including short-term medical insurance plans, and guaranteed-issue and underwritten health benefit insurance plans. Health Plan Intermediaries Holdings, LLC ("HPIH") is one of the
Company's subsidiaries.
According to the Complaint, Avon is a global manufacturer and marketer of beauty and related products. Avon's reportable segments are based on geographic operations in four regions: Europe, Middle East & Africa; South Latin America; North Latin America; and Asia Pacific. During 2016, Avon had sales operations in 57 countries and territories. Brazil is Avon's largest market, measured by revenue and number of sales representatives. In 2016, Brazil revenue was $1.2 billion, approximately 21% of Avon's total revenues. No other country accounts for more than 10% of Avon's total revenues.
According to the Complaint, Bristow is an industrial aviation services provider with major transportation operations in the North Sea, Nigeria and the Gulf of Mexico, and in most other major offshore energy producing regions of the world.
According to the Complaint, Uxin is a used car e-commerce platform in China. The Company has two segments: Uxin Auction (or 2B business) sells used cars to dealers, and Uxin Used Car (or 2C business) sells used cars to consumers.
According to the Complaint, Wirecard, a technology company, purports to provide outsourcing and white label solutions for electronic payment transactions worldwide.
According to the Complaint, Revolution Lighting purports to design and manufacture light-emitting diode ("LED") lighting solutions for industrial, commercial, and government markets.
According to the Complaint, Arlo provides smart connected devices that can purportedly monitor environments in real-time using its cloudbased platform. This is accomplished by using a Wi-Fi or cellular network Internet connection in the Americas, Europe, the Middle-East, Africa, and the Asia Pacific regions. By using Arlo's cloud-based platform, consumers may engage in real-time with their families and businesses from any location with an internet connection. Arlo also offers Wi-Fi- and LTE-enabled cameras, advanced baby monitors, and smart security lights.
According to the Complaint, as of September 2017, Sogou was China's fourth largest Internet company based on MAU. By mobile queries, the Company's Sogou Search engine is the second largest search engine in China.
Plaintiff's law firm issued a press release on January 7, 2019, announcing the filing of the lawsuit. According to the press release, Liberty Health Sciences Inc. ("Liberty" or the "Company") was incorporated under the Business Corporations Act (British Columbia) on November 9, 2011, as SecureCom Mobile Inc. The Company's principal business activity is the production and distribution of medical cannabis through its wholly-owned subsidiary DFMMJ LLC (d/b/a Liberty Health Sciences Florida Ltd.). Aphria Inc., which also produces and distributes cannabis, has had long-standing ties with Liberty, starting from the very beginning of both companies.