Allegations
(1) the Company covertly participated in the “the largest public corruption case in Ohio history”; (2) the Company secretly funneled substantial funds to Ohio political organizations and politicians to bribe politicians to pass Ohio House Bill 6 (“HB6”), which benefited the Company and its coal-fired generation assets; (3) the Company partially funded a massive, misleading advertising campaign in support of HB6 and in opposition to a ballot initiative to repeal HB6 by passing substantial sums through a web of dark money entities and front companies in order to conceal the Company’s involvement; (4) the Company aided in subverting a citizens’ ballot initiative to repeal HB6; (5) as a result of the foregoing, defendants' statements regarding the Company’s regulatory and legislative efforts were materially false and misleading; 6) as a result of the foregoing, the Company would face increased scrutiny; (7) the Company was subject to undisclosed risk of reputational, legal, and financial harm; (8) the bribery scheme would jeopardize the benefits the Company sought brought by HB6; (9) as opposed to the its repeated public statements regarding a move to clean energy, the Company sought a dirty energy bailout; (10) as opposed to the Company’s repeated public statements regarding protection of its customers’ interests, the Company sought an extra and state-mandated surcharge on its customers’ bills; and (11) as a result of the foregoing, Defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.