The complaint alleges that Target made materially false and/or misleading statements and/or failed to disclose: (i) the true extent of Target’s difficulty maintaining a balanced inventory of in-demand goods, despite its insights into changing consumer preferences; (ii) that Target was severely impacted by changing consumer preferences; (iii) that Target’s inventory mix was significantly more sensitive to changing consumer preferences due to Target’s practice of buying larger quantities ahead of season, and was therefore at significant risk of having to use markdowns to sell out-of-demand goods; and (iv) that, as a direct result of these changing preferences, Target’s inventory increasingly became out-of-balance and overweight in bulky and unsellable goods throughout the Class Period forcing Target to markdown its out-of-demand goods, thereby negatively impacting revenue.
