The filed complaint alleges that defendants made false statements and/or concealed that: (1) the growth of Intel Foundry Services was not indicative of revenue growth reportable under the Internal segment; (2) the Foundry experienced significant operating losses in 2023; (3) the Foundry experienced a decline in product profit driven by lower internal revenue; (4) as a result the Foundry model would not be a strong tailwind to the Company’s IFS strategy; and (5) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.