The complaint alleges that the defendants violated federal securities laws by issuing material misrepresentations to the market concerning the company's financial condition, thereby artificially inflating the price of Pilgrim's Pride stock.

Specifically, the complaint alleges that defendants knew the following material undisclosed information which contradicted their public statements: (1) that the company's hedges to protect it from adverse changes in costs were not working and actually harming the company's results more than helping; (2) that the company's inability to continue to use illegal workers would adversely affect its margins; (3) that the company's financial performance was continuing to deteriorate rather than improve, such that the company's capital structure was threatened; (4) that the company was in a much worse position than its competitors due to its inability to raise prices for customers sufficient to offset cost increases, whereas its competitors were able to raise prices to offset higher costs affecting the industry; and (5) that the company had not made sufficient changes to its business to succeed in the more difficult industry conditions.

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After the market closed on September 24, 2008, Pilgrim's Pride issued a press release to comment on recent trading activity in the company's common stock. The company revealed that as a result of high feed-ingredient costs, continued weak pricing and demand for breast meat, and the significant negative impact of hedged grain positions during the quarter, the company had notified its lenders that Pilgrim's Pride expected to report a significant loss in the fiscal fourth quarter. On this news, shares plunged to $3.84 per share on September 25, 2008, a significant decline from the closing price of $10.26 per share two days earlier on September 23, 2008.