The complaint alleges that prior to and during the Class Period, defendants engaged in a scheme to defraud and made numerous materially false and misleading statements and omissions to investors regarding the Company’s operations and its business and financial condition and outlook. Specifically, defendants misled investors by failing to disclose that the Company had utilized a “defeat device” in certain of its diesel cars that allowed such cars to temporarily reduce emissions during testing, while achieving higher performance and fuel economy, as well as discharging dramatically higher emissions, when testing was not being conducted. The use of this device allowed Volkswagen to market its diesel vehicles to environmentally conscious consumers, increasing its sale of diesel cars in the United States and abroad and, as a result, its profitability. As a result of defendants’ scheme and false and misleading statements and omissions, Volkswagen’s ordinary and preferred ADRs traded at artificially inflated prices during the Class Period, reaching highs of $54.82 and $56.55 per ADR, respectively, on December 30, 2013.