The filed complaint alleges that defendants made false statements and/or concealed that: (a) the nature and magnitude of Seagate’s hard disk drive (“HDD”) sales to Huawei Technologies Co. Ltd. (“Huawei”), including that Seagate experienced a significant acceleration in sales to Huawei immediately after the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) rules went into effect and Seagate’s competitors stopped selling to Huawei; and (b) the underlying details of Seagate’s HDD manufacturing process, including the use of covered U.S. software and technology in “essential ‘production’” processes, rendered its sales to Huawei in violation of the BIS export rules. As a result, Seagate was in blatant violation of the BIS export rules which resulted in an ongoing investigation by the U.S. Department of Commerce and exposed Seagate to hundreds of millions of dollars in fines and penalties.