The Complaint alleges that during the Class Period, Defendants made false and misleading statements and/or failed to disclose adverse information about the Company’s business and prospects, including that the Company was using a network of specialty mail-order pharmacies that it actually controlled to prop up sales of its high-priced drugs and to keep patients and their insurance companies from switching to less costly generic drugs, that Valeant’s undisclosed use of specialty pharmacies left it subject to increased regulatory risks, and that without the use of the specialty pharmacies, Valeant’s financial performance and Class Period financial guidance would have been negatively impacted. As a result of these false and misleading statements and/or omissions, Valeant stock traded at artificially inflated prices during the Class Period, reaching over $260 per share.

On October 19, 2015, the Company issued a press release reporting its third quarter 2015 financial results. On the same day, Valeant hosted an earnings call during which, for the first time, Defendants revealed the previously undisclosed and direct relationship between Valeant and certain specialty pharmacies. On this news, the price of Valeant common stock fell over 10% in one day, from a close of $163.83 per share on October 19, 2015 to a close of $146.74 per share on October 20, 2015. Additional news concerning Valeant’s unique relationships with specialty pharmacies reached the market on October 21, 2015, causing the price of Valeant stock to drop sharply, falling further… to a close of $118.61 per share.

On behalf of all those who purchased Valeant Pharmaceuticals International, Inc. (‘Valeant” or the “Company”) equity securities and senior notes in the United States during the Class Period.