Allegations
(a) the Victoria’s Secret and PINK businesses were having a material adverse effect on the Company’s cash flow, liquidity and debt levels; (b) Defendants lacked a reasonable basis for their positive statements about the ability of the Company to sustain its dividend; (c) the MD&A disclosures in filings L Brands made with the SEC were materially false and misleading; (d) the risk factor disclosures in filings L Brands made with the SEC were materially false and misleading; (e) the representations about L Brands’ disclosure controls in filings the Company made with the SEC were materially false and misleading; (f) the certifications issued by Defendants Wexner and Burgdoerfer on L Brands disclosure controls were materially false and misleading; and (g) based on the foregoing, Defendants lacked a reasonable basis for their positive statements about L Brands’ then-current business operations and future financial
prospects.