According to the Complaint, Cheetah Mobile Inc. ("Cheetah" or the Company) is a mobile Internet company with global market coverage. It has attracted hundreds of millions of monthly active users through its mobile utility products such as Clean Master and Cheetah Keyboard, casual games such as Piano Tiles 2, Bricks n Balls, and the live streaming product LiveMe.

The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company’s business, operational and compliance policies. The Complaint specifically alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) Cheetah’s apps had undisclosed imbedded features which tracked when users downloaded new apps; (ii) Cheetah used this data to inappropriately claim credit for having caused the downloads; (iii) the foregoing features, when discovered, would foreseeably subject the Company’s apps to removal from the Google Play store; (iv) accordingly, Cheetah’s Class Period revenues were in part the product of improper conduct and thus unsustainable; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.