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Allegations
(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.