The filed complaint alleges that defendants made false statements and/or concealed that: (1) touting the Company’s purported visibility into utilization trends and medical costs; (2) failing to disclose increased medical costs that Agilon had incurred prior to and during the class period due to higher utilization of healthcare by MA patients; (3) falsely stating that its incurred-but-not-reported reserve was adequate; (4) making false and misleading statements about the effectiveness of its business model; (5) issuing overly optimistic financial guidance; and (6) issuing risk disclosures that were materially false and misleading because they characterized adverse facts that had already materialized as mere possibilities.