The filed complaint alleges that defendants made false statements and/or concealed that: (i) several of CAE’s pre-COVID fixed-price defense contracts had incurred severe cost overruns due to supply chain and labor issues – as the segment was significantly impacted by the pandemic – which dented the segment’s profit and operating margin; and (ii) CAE failed to successfully reduce hard costs and achieve a sufficient level of operational efficiency, particularly with respect to such contracts, necessitating a re-baselining of the defense business and significant associated charges.