HP investors may receive additional information about the case by clicking the link "Submit Your Information" above.
HP is a global provider of personal computers, printers and related supplies, solutions, and services. HP conducts its business primarily through two segments: Personal Systems and Printing. HP’s Printing segment includes the Supplies business unit which comprises consumable products, including ink and laser cartridges, for recurring use in consumer and commercial printing hardware. The Supplies business has been a significant revenue driver for HP.
Prior to the Class Period, on June 21, 2016, HP reported that its Supplies business was facing numerous challenges. As a result, HP announced a one-time investment of $450 million to buy back supplies from its channel partners to better align supplies inventory levels with demand, with the goal of stabilizing supplies revenue by the end of fiscal 2017. HP also announced the fundamental shift in its Supplies business from a push strategy to a pull strategy, which involves aligning channel supplies inventory levels with current demand and marketing efforts to drive print relevancy and strengthen HP’s Supplies brand value.
The Class Period commences on February 23, 2017, the next trading day after HP issued a press release after the close of market on February 22, 2017, which it also filed with the SEC on a Form 8-K, announcing its financial results for the first quarter of fiscal 2017.
At the start of the Class Period, HP assured investors that its new approach of managing and aligning demand and inventory in its Supplies business would avert the types of problems that necessitated the $450 million buy-back. The centerpiece of this new approach was focused on what HP called its “four-box model.” For several years, HP measured its Supplies business through this model, which focuses on the four key drivers of revenue growth: in-store base, usage, market share, and price.
HP’s four-box model became the primary focus of HP and its investors because HP assured investors that its use of the four-box model enabled it to accurately assess demand for products in its Supplies business and manage the inventory placed in its sales and distribution channels. Throughout the Class Period, HP emphasized the four-box model as an accurate, reliable tool to determine demand and revenue in the Supplies business, and reassured investors that, based on the four-box model, HP had a “clear line of sight to supply stabilization.” Defendants repeatedly highlighted the reliability of HP’s four-box model and the revenue growth of the Supplies business, touting their “continued confidence in the predictive value of the four box model” and stating that HP’s “Supplies revenue is in line with the expectations that we set, and that our 4-box model continues to drive predictability.”
The truth began to emerge on February 27, 2019, after the close of trading, when HP reported that total Supplies revenue was down 3%, with a 9% decline in HP’s Europe, the Middle East, and Africa (“EMEA”) market, for the first quarter of fiscal year 2019. On an earnings call held that day, HP management attributed the shortfall to weaker than predicted demand from commercial customers in EMEA driven by an increase in online sales, where HP had a lower market share and faced more competition from cheaper third-party alternatives than in the U.S. HP, however, admitted to a larger problem with its four-box model: it had been using incorrect data concerning inventory, market share, and pricing assumptions. Thus, contrary to its previous statements, HP in fact had limited “visibility into the downstream channel ecosystem.” As a result, HP had too much inventory in its Supplies channel network that was not selling through. HP also revealed that it lacked telemetry data - data provided automatically by remote units, such as printers that have been sold to customers, which apprise HP about the level of usage and need for new toner - to determine reliable market share assumptions for its Supplies business. Following this news, HP’s stock price declined from $23.85 per share to $19.73 per share, or over 17%, on high trading volume.
Then, on August 22, 2019, after the market closed, HP announced in a press release, also filed on a Form 8-K with the SEC, that Dion J. Weisler (“Weisler”), HP’s President and Chief Executive Officer, would step down at the end of October 2019. HP also announced disappointing earnings results for the third quarter of fiscal year 2019, with Supplies revenue down 7% year-over-year. Management also revised Supplies revenue guidance even further down, to 4% or 5% down for fiscal year 2019 from previous guidance of 3%. Following this news, the price of HP’s stock dropped nearly 6%, from $18.93 per share to $17.81 per share, on unusually high trading volume.
Finally, on October 3, 2019, after the market closed, HP announced that it was “departing from the purely transactional Supplies-centric business model” and transitioning to a hardware-driven business. The new business model gives customers the choice between a discounted HP printer that can only function with HP Supplies or a higher-priced HP printer with the option to choose third-party cartridges. Under the new business model, HP would abandon its use of the four-box model as HP de-emphasized Supplies revenue and instead would focus on “the key metrics [of] service growth and operating profit dollars, which better reflect the system profitability.” HP also announced mass layoffs as part of a major company restructuring, in which it expects to cut between 7,000 to 9,000 positions, or up to 16% of its global workforce, over three years. Following this news, the price of HP’s stock dropped from $18.40 per share to $16.64 per share, or nearly 10%, on unusually high trading volume.
The complaint alleges that, throughout the Class Period, the defendants knew that the four-box model was severely deficient and not a strong predictor of Supplies demand and outcomes, because HP lacked telemetry data from its commercial printers and had to use unreliable and stagnant market share data to develop assumptions for the four-box model. The complaint also alleges that the defendants knew the lack of telemetry data for commercial printing was a critical shortcoming of the four-box model because HP possessed telemetry data on its personal printing side and knew it was a necessary element for an accurate understanding of the Supplies channel. As a result, the Supplies inventory in HP’s channel exceeded demand by at least $100 million and HP’s Supplies revenue growth was grossly inflated.
If you are a member of the class described above, you may no later than April 20, 2020 move the Court to serve as lead plaintiff of the class, if you so choose.
A lead plaintiff is a representative party that acts on behalf of other class members in directing the litigation. In order to be appointed lead plaintiff, the Court must determine that the class member’s claim is typical of the claims of other class members, and that the class member will adequately represent the class. Your ability to share in any recovery is not, however, affected by the decision whether or not to serve as a lead plaintiff. Returning the attached form or communicating with any counsel is not necessary to participate or share in any recovery achieved in this case. Any member of the purported class may move the court to serve as a lead plaintiff through counsel of his/her choice, or may choose to do nothing and remain an inactive class member.
Kessler Topaz Meltzer & Check, LLP has filed a complaint in this matter (see “View Complaint” above to read full complaint). If you wish to discuss this action or have any questions concerning this notice or your rights or interests with respect to these matters, please contact Kessler Topaz Meltzer & Check, LLP toll free at 1-844-887-9500 or 1-610-667-7706, or via e-mail at email@example.com. If you would like additional information about the suit, please click on the link "Submit Your Information" above and fill out the form as promptly as possible.
Kessler Topaz Meltzer & Check, LLP
James Maro, Jr., Esq.
Adrienne Bell, Esq.
280 King of Prussia Road
Radnor, PA 19087