According to the Complaint, CAE Inc. is a technology company that deploys software-based simulation training and critical operations support solutions. The Company principally operates in two segments: (i) Civil Aviation, whereby the company provides comprehensive training solutions for flight, cabin, maintenance and ground personnel, and a complete range of flight simulation training devices, among other training operations solutions and optimization software; and (ii) Defense, whereby the company provides independent training and simulation solutions for global defense and security forces.

The Complaint alleges that, throughout the Class Period, Defendants made materially false and misleading statements concerning significant cost overruns in CAE’s Defense segment caused by several fixed-price, long-term Defense contracts entered prior to the COVID-19 pandemic. The Complaint further alleges that when Defendants’ prior misrepresentations and fraudulent conduct were disclosed to the market on August 10, 2022, November 14, 2023, February 14, 2024, and May 21, 2024, the price of CAE stock fell precipitously, as the prior artificial inflation came out of the price and that as a result of their purchases of CAE stock during the Class Period, Plaintiff and other members of the Class suffered economic loss, i.e., damages, under the federal securities laws.