According to the Complaint, Merck & Co., Inc. is a global healthcare company that operates through two segments, Pharmaceutical and Animal Health, with a significant focus on prescription medications. This class action was filed against Merck and three individual Defendants.

During the Class Period, Defendants provided investors with material information concerning Merck’s expected revenue of $11 billion from sales of Gardasil by 2030. Defendants’ statements included, among other things, confidence in Merck’s purported ability to utilize successful consumer activation and education efforts on the benefits of Gardasil in order to drive demand and capitalize on eligible populations for vaccination, resulting in confidently optimistic reports and forecasts of Gardasil’s growth in China.

The Complaint alleges Defendants provided these overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of Gardasil’s demand in China; notably, that Merck lacked visibility into demand for Gardasil in China among eligible and otherwise targeted populations, resulting in the inflated inventory of its distributor, Zhifei. The Complaint further alleges that such statements absent these material facts caused Plaintiff and other shareholders to purchase Merck’s securities at artificially inflated prices.