Allegations
(1) the planned “workforce optimization” plan involved implementing arbitrary quotas; (2) the plan would cut thousands of jobs at the Company; (3) jobs that were particularly at risk of being cut were held by longer-tenured, knowledgeable, and highly compensated senior personnel; (4) these job terminations were selectively timed to artificially inflate reported earnings and other financial metrics; (5) at the time of the formation of DXC Technology Company, J. Michael Lawrie (the incoming President, Chief Executive Officer, and Chairman of the Board at DXC) had forecasted plans for a $2.7 billion workforce reduction in the first year; (6) as a result of these workforce terminations, the Company was unlikely to deliver on client contracts; (7) that, as a result of the foregoing, the Company’s clients would be dissatisfied and the relationships would be impaired; and (8) as a result of the foregoing, Defendants’ positive statements about the Company’s business, operations, and prospects, were materially misleading and/or lacked a reasonable basis.