According to the Complaint, agilon health, inc. is a healthcare company.

On March 18, 2021, Agilon filed with the SEC a registration statement for the IPO on Form S-1, which was declared effective on April 14, 2021. On April 16, 2021, Agilon filed with the SEC a prospectus for the IPO on Form 424B4, which incorporated and formed part of the Registration Statement. In the IPO, Agilon sold over 53 million shares of Agilon stock at $23 per share (which included the full exercise of the underwriters’ overallotment option), for over $1.2 billion in gross offering proceeds.

The Complaint alleges that Defendants throughout the Class Period and in the IPO’s offering documents made false and/or misleading statements and/or failed to disclose that: (i) agilon’s business model, purportedly focused on patient care rather than fee-for-service, was unable to provide the cost savings and the mitigation of medical expenses represented to investors; (ii) agilon’s purported historical cost savings portrayed to investors in connection with the IPO were short-term effects of the COVID-19 pandemic and not indicative of the cost controls and incentives ostensibly inherent in agilon’s business model; (iii) as a result of the above, agilon suffered from a material, undisclosed risk of higher utilization and medical claims rates once the short-term effects of the COVID-19 pandemic waned and the providers in agilon’s network were poised to experience an upsurge in patient demand for medical services materially above the historical rate portrayed in the IPO offering documents; (iv) agilon suffered from materially higher utilization and medical claims rates throughout the Class Period as compared to prior year periods as patients who had delayed elective procedures and otherwise utilizing medical benefits during the COVID-19 pandemic sought treatment; (v) agilon’s business model, purportedly focused on patient care rather than fee-for-service, had not insulated agilon from these adverse cost trends as claimed by defendants, and agilon was in fact suffering cost trends that were up to 3x higher in key areas like specialist costs, outpatient surgeries, and Part B drugs as compared to 2022; (vi) these material, adverse cost trends were not moderating, but in fact worsening as agilon progressed through the year; (vii) agilon had suffered tens of millions of dollars in excess costs related to patient supplemental benefits and over $60 million in excess costs related to agilon’s core medical services that had not been disclosed to investors; (viii) agilon had suffered tens of millions of dollars in prior year development claims that had not been revealed to investors; (ix) agilon’s historical medical margins and adjusted EBITDA had been artificially inflated and materially misrepresented to investors; and (x) agilon’s 2023 medical margin and adjusted EBITDA guidance, its 2024 cash flow guidance, and its 2026 long-term guidance was not achievable and lacked a reasonable basis in fact.