According to the filed complaint, defendants represented to investors that GSK removed Zantac from the market “[b]ased on information available at the time and correspondence with regulators.” GSK also stated that it was “continuing with investigations into the potential source of NDMA.” Defendants also assured investors that “GSK, the FDA, and the EMA [European Medicines Agency] have all independently concluded that there is no evidence of a causal association between ranitidine therapy and the development of cancer in patients,” findings that were “consistent with other ranitidine data published prior to 2019.” Finally, defendants claimed that they could not “quantify or reliably estimate the liability.” These representations were materially false or misleading. In truth, GSK was fully aware of the source of NDMA and had been for nearly 40 years before withdrawing Zantac from the market.