According to the filed complaint, defendants made false and/or misleading statements and/or failed to disclose that: In truth, defendants knew of, or recklessly disregarded, problems associated with the Enterprise Resource Planning (ERP) system that would hinder its successful implementation. Despite those issues, Lamb Weston pushed ahead with its implementation of an ERP system that was not ready to go live, knowing that a premature roll-out would have a material negative impact on the Company’s business and operations. As a result, the statements concerning its business, operations, and prospects, including its financial guidance for fiscal 2024, lacked a reasonable factual basis. In addition, to the extent the Company purported to warn of risks regarding the negative impacts from an unsuccessful implementation of the ERP system, defendants omitted that such risks had already begun to materialize.