In re HP Inc. Securities Litigation

BACKGROUND

I. Factual Background

21 The following allegations are taken from the Amended Complaint (“AC”), which the Court 22 must treat as true for the purposes of this motion. 23 This matter arose in connection with statements by corporate executives of HP Inc. (“HP”) 24 regarding HP’s Four Box Model. HP is a global provider of personal computers, printers, and 25 related supplies. Dkt. No. 35, AC ¶¶ 2, 35. In 2015, HP announced the Four Box Model, which 26 allowed HP to assess supplies revenue based on four factors: installed base, usage, printer supplies 27 market share or supplies attach, and price of supplies. Id. ¶ 69. According to HP, the Four Box Model used various forms of data and analytics to accurately predict supplies revenue. Id. ¶ 70. During the class period, between February 23, 2017 and October 3, 2019, HP told investors that the Four Box Model predicted HP’s supplies revenue would stabilize. Id. ¶¶ 88, 111, 242, 344. However, on February 27, 2019, HP’s CEO, defendant Weisler, admitted that HP lacked statistically sufficient, accurate, and otherwise reliable telemetry data from HP’s toner-based printer, meaning that the…