This case arises out of allegations that Defendants violated Sections 14(e), 20A, and/or 20(a) of the Securities Exchange Act of 1934. Specifically, the Action alleges that, during the Class Period from February 25, 2014 through April 21, 2014, Pershing Square acquired or caused the acquisition of a 9.7% stake in Allergan while in possession of material nonpublic information relating to a tender offer to be made by Valeant for Allergan. On April 21 and 22, 2014, Valeant announced its takeover bid and Pershing Square disclosed its stake. Allergan’s stock price increased about 15% in the immediate aftermath of that announcement. Pershing Square’s profits from its Class Period transactions grew to well over $2 billion after a “white knight,” Actavis plc, agreed to acquire Allergan for cash and stock valued at approximately $219 per Allergan share. Of this amount, Pershing Square paid approximately $400 million to Valeant pursuant to a February 2014 agreement that Pershing Square would share its gains with Valeant in the event that a competing offer for Allergan was successful.

The Action was commenced in December 2014. On May 5, 2015, the Court issued an Order appointing the State Teachers Retirement System of Ohio (“Ohio STRS”) and the Iowa Public Employees Retirement System (“IPERS”) as “Lead Plaintiffs” pursuant to the Private Securities Litigation Reform Act of 1995. In the same Order, the Court approved Lead Plaintiffs’ selection of Bernstein Litowitz Berger & Grossmann LLP and Kessler Topaz Meltzer & Check, LLP as “Co-Lead Counsel” for the Class, and consolidated all related actions.

The operative complaint in the Action, the Second Amended Complaint (the “Second Amended Complaint” or “Complaint”), was filed on April 20, 2016. The Complaint asserts, among other things, claims under Sections 14(e) and 20A of the Securities Exchange Act of 1934 and Rule 14e-3 promulgated thereunder, which, with certain exceptions, prohibits insider trading by a person while in possession of material nonpublic information relating to a tender offer, after a person (the “offering person”) has taken a substantial step or steps toward commencement of a tender offer. Lead Plaintiffs seek damages arising from Defendants’ alleged violation of these provisions based on the difference between the selling price actually received by the Class for their Allergan shares and the true value of the shares had there been no material omissions and misconduct by Defendants.

The “Class,” as certified by the Court, consists of:

All persons who sold Allergan, Inc. ("Allergan") common stock contemporaneously with purchases of Allergan common stock made or caused by Defendants during the period February 25, 2014 through April 21, 2014, inclusive (the “Class Period”) and were damaged thereby except for certain persons and entities excluded from the Class by definition.

Please read the Notice of Pendency of Class Action to fully understand your rights and options.

Important Deadlines

September 11, 2017
Exclusion Deadline. To exclude yourself from the Class, you must mail your exclusion request, postmarked by no later than September 11, 2017, in accordance with the instructions in the Notice of Pendency of Class Action.
September 11, 2017
Notice of Appearance with the Clerk. If you retain separate counsel in connection with this matter, such counsel must enter an appearance on your behalf pursuant to Rule 23(c)(2) of the Federal Rules of Civil Procedure, as set out in the Notice of Pendency of Class Action.

Class Counsel

As a member of the Class, you will be represented by Class Counsel, who are:

Richard D. Gluck BERNSTEIN LITOWITZ BERGER & GROSSMANN LLP 12481 High Bluff Drive, Suite 300 San Diego, CA 92130 (858) 793-9323 Eli R. Greenstein Stacey M. Kaplan Rupa Nath Cook KESSLER TOPAZ MELTZER & CHECK, LLP One Sansome Street, Suite 1860 San Francisco, CA 94104 (415) 400-3000
Mark Lebovitch Jeremy P. Robinson Michael D. Blatchley Edward G. Timlin BERNSTEIN LITOWITZ BERGER & GROSSMANN LLP 1251 Avenue of the Americas, 44th Floor New York, NY 10020 (800) 380-8496 (212) 554-1400 Lee Rudy Josh D’Ancona Justin O. Reliford KESSLER TOPAZ MELTZER & CHECK, LLP 280 King of Prussia Road Radnor, PA 19087 (888) 299-7706 (610) 667-7706