According to the filed complaint, defendants made false statements and/or concealed that Scotts had an oversupply of inventory that far exceeded consumer demand. Recognizing that problem, Scotts executives engaged in a scheme to saturate the Company’s sales channel with more product than those retailers could sell through to end users, a practice that required Scotts sales personnel to pressure retailers to purchase more inventory than they wanted or needed. Ultimately, Scotts was only able to satisfy the covenants through the channel stuffing scheme.