Allegations
(a) the U.S.-China trade war had negatively impacted demand for iPhones and Apple’s pricing power in greater China, one of Apple’s most important growth markets; (b) the rate at which Apple customers were replacing their batteries in older iPhones rather than purchasing new iPhones was negatively impacting Apple’s iPhone sales growth; (c) as a result of slowing demand, Apple had slashed production orders from suppliers for the new 2018 iPhone models and cut prices to reduce inventory; (d) unit sales for iPhone and other hardware was relevant to investors and the Company’s financial performance, and the decision to withhold such unit sales was designed to and would mask declines in unit sales of the Company’s flagship product; and (e) as a result of the foregoing, defendants lacked a reasonable basis in fact when issuing the Company’s revenue outlook for the first quarter 2019 and/or making the related statements concerning demand for its products, as Apple’s business metrics and financial prospects were not as strong as defendants had led the market to believe.