Allegations
The filed complaint alleges that ZoomInfo Technologies Inc. made materially false and/or misleading statements and/or failed to disclose that: (a) ZoomInfo’s financial and operational results during the Class Period had been temporarily inflated by the ephemeral effects of the COVID-19 pandemic, which had pulled-forward demand for the Company’s database of digital contact information; (b) material portions of ZoomInfo’s existing customer base were attempting to either substantially reduce their use of the Company’s product or abandon it altogether; (c) that ZoomInfo had used manipulative and coercive auto-renew policies and threats of litigation to force customers into remaining with the Company for an additional contractual term even though such customers did not want to; (d) ZoomInfo’s coercive customer retention tactics had materially damaged the Company’s customer relationships, client franchise, and competitive advantages, and created a hidden demand cliff for costumer contract renewals in future periods; and (e) as a result of (a)–(d), above, ZoomInfo’s reported revenues, operating income, and customer and retention metrics were materially overstated.