City of Miami Gen. Employees' & Sanitation Employees' Ret. Trust v. RH, Inc.

I. BACKGROUND

The facts at issue in this case, as pleaded in plaintiffs' 100-page Consolidated Class Action Complaint ("CCAC"), (Dkt. No. 45), are well-known to the parties. Relevant allegations from the CCAC are set forth below.

*1034 A. RH's Business and Procurement Structure

RH is a Delaware corporation headquartered in Corte Madera, California, with approximately 41 million outstanding shares. ( Id. at ¶ 21.) Its fiscal year ("FY") concludes on January 31 of each year. RH is a retailer of luxury home furnishings such as couches, chairs, tables, lamps, and rugs. ( Id. ¶ 25.) It sells products through its website; retail and outlet stores; and "Source Books" which are voluminous, glossy product catalogs distributed to potential customers. ( Id. ) As of April 29, 2017, the RH operated 85 retail stores and 28 outlets. ( Id. )

During the Class Period, RH did not manufacture any of the products it sold. ( Id. ¶ 28.) Instead, RH contracted with third-party manufacturers. ( Id. ) Most of RH's manufacturers (frequently referred to as "vendors") were located overseas: RH sourced approximately 69% of its inventory from vendors in Asia in FY2013 and 82% in FY2015. Plaintiffs aver…