The Complaint alleges that throughout the Class Period, Defendants made false and/or misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operations, and prospects. Specifically, Defendants made false and/or misleading statements and/or failed to disclose that: (i) flaws in the Company’s manufacturing processes, supply chain, electronic security measures, and/or quality control rendered at least 3.1 million Chrysler cars and trucks unsafe to drive; (ii) the Company’s slow completion rates for recalls, slow or inadequate notifications to consumers, and faulty approaches to addressing safety issues and improper actions by dealers were not in compliance with federal laws and regulations; and (iii) as a result of the foregoing, Defendants’ statements about Chrysler’s business, operations, and prospects were false and misleading and/or lacked a reasonable basis.

On June 28, 2015, the Company announced a recall that included model-year 2015 Jeep Grand Cherokee and Dodge Durango SUVs. The Company advised approximately 65 vehicle owners to immediately stop driving their vehicles. On this news, the Company’s stock fell $1.06, or roughly 6.8 percent, to close at $14.53 on June 29, 2015.

On July 24, 2015, Chrysler issued a recall affecting approximately 1.4 million Jeep Grand Cherokee and Dodge Durango SUVs after it was demonstrated that a security flaw in the vehicles’ systems rendered the vehicles vulnerable to remote electronic manipulation (“hacking”), including cutting the vehicle’s brakes, shutting down the vehicle’s engine, steering the vehicle off the road, and shutting down the vehicle’s electronics systems. On this news, the Company’s stock fell $0.39, or 2.5 percent, to close at $15.15 on July 24, 2015.

On July 26, 2015, the NHTSA announced its imposition on the Company of a record $105 million fine in connection with the Company’s handling of 23 previous recalls affecting more than 11 million vehicles. The NHTSA penalties were tied to violations in an array of areas, including misleading regulators, inadequate repairs, and failure to alert affected car owners in a timely manner. On this news, the Company’s stock fell $0.74, or roughly 4.9 percent, to close at $14.41 on July 27, 2015.

On September 4, 2015, Chrysler issued a recall notice affecting approximately 7,810 Jeep Renegade SUVs, reflecting further hacking concerns. On this news, the Company’s shares fell $0.27, or 1.9 percent, to close at $13.60 on September 4, 2015.

On September 10, 2015, Chrysler issued further recall notices affecting nearly 1.7 million recent-model Ram pickups, addressing faulty wiring harnesses, airbags, and steering components.