According to the Complaint, Petco Health and Wellness Company, Inc. (“Petco”) is a specialty retailer that offers a variety of pet products, services, and solutions, including consumable and non-consumable products via physical and digital stores and in-store veterinary and grooming services. One of Petco’s key business metrics is comparable sales—also referred to as same-store sales or “comp”—which measures the change in period-over-period net sales from physical locations and digital sites that have been open for the applicable period. This class action was filed against Petco and six of its Officers.

The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding Petco’s business, operations, and prospects. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) Petco’s pandemic-related tailwinds were unsustainable, as was its business model of selling primarily premium and/or high-grade pet food; (ii) accordingly, the strength of Petco’s differentiated product strategy was overstated; (iii) Defendants downplayed the true scope and severity of the foregoing issues, the magnitude of changes needed to rectify those issues, and the likely negative impacts of their mitigation strategy on Petco’s comparable sales metric; (iv) accordingly, Defendants overstated Petco’s ability to deliver sustainable, profitable growth; and (v) as a result, Defendants’ public statements were materially false and misleading at all relevant times.