According to the Complaint, UnitedHealth Group Incorporated describes itself as a "health care and well-being company with a mission to help people live healthier lives and help make the health system work better for everyone. The Company’s two distinct, yet complementary businesses — Optum and UnitedHealthcare — are working to help build a modern, high-performing health system through improved access, affordability, outcomes and experiences for the individuals and organizations the Company is privileged to serve." This lawsuit was filed against UnitedHealth and two of its Officers.

The Complaint alleges that during the Class Period, Defendants made false and/or misleading statements and/or failed to disclose that: (1) UnitedHealth had, for years, engaged in a corporate strategy of denying health coverage in order to boost its profits, and ultimately, its share price; (2) this anti-consumer (and at times unlawful) strategy resulted in regulatory scrutiny (as well as public angst) against UnitedHealth, which ultimately resulted in the murder of the former CEO; (3) animus towards UnitedHealth was such that, subsequent to the murder of the former CEO, many Americans openly celebrated his demise, expressed admiration for his accused killer, and/or otherwise demanded that UnitedHealth change its strategy even if they condemned the former CEO's killing; (4) the foregoing regulatory and public outrage caused UnitedHealth to change its corporate practices; (5) notwithstanding the foregoing, UnitedHealth recklessly stuck with the guidance it issued the day before the former CEO's murder, which was unrealistic considering the Company’s changing corporate strategies; and (6) as a result, Defendants’ public statements were materially false and/or misleading at all relevant times.