Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 1 of 21
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`BLOCK & LEVITON LLP
`Whitney E. Street (CA Bar No. 223870)
`100 Pine Street, Suite 1250
`San Francisco, CA 94111
`Telephone: (415) 968-1852
`Fax: (617) 507-6020
`whitney@blockleviton.com
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`LOWEY DANNENBERG, P.C.
`Andrea Farah
`Christian Levis
`44 South Broadway, Suite 1100
`White Plains, NY 10601
`Telephone: 914-997-0500
`Fax: (914) 997-0035
`Email: afarah@lowey.com
`clevis@lowey.com
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`Attorneys for Plaintiff
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
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`PAUL HESSONG, on Behalf of Himself
`and All Others Similarly Situated,
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`Plaintiff,
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`PINTEREST, INC. and BEN SILBERMANN
`and TODD MORGENFELD
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`Defendants.
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`v.
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`Case No.
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`CLASS ACTION COMPLAINT
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` CLASS ACTION
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`JURY TRIAL DEMANDED
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`CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL
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`Plaintiff, Paul Hessong (“Plaintiff”), individually and on behalf of all others similarly
`situated, by and through his undersigned counsel, hereby brings this Class Action Complaint for
`Violation of Federal Securities Law (“Complaint”) against (i) Pinterest, Inc. (“Company” or
`“Pinterest”); (ii) Ben Silbermann, the Company’s co-founder, President and Chief Executive Officer
`(“CEO”); (iii) Todd Morgenfeld, the Company’s Chief Financial Officer and Head of Business
`Operations (“CFO”) (Defendants Silbermann and Morgenfeld are collectively referred to as
`“Individual Defendants”, and together with the Company as “Defendants”) based upon, inter alia,
`the investigation conducted by and under the supervision of Plaintiff’s counsel, which included a
`review of the Company’s public documents, conference calls, and announcements, United States
`(“U.S.”) Securities and Exchange Commission (“SEC”) filings, wire and press releases published by
`and regarding the Company, analysts’ reports and advisories about the Company and readily
`obtainable information. Plaintiff’s counsel’s investigation into the matters alleged herein is ongoing
`and many relevant facts are known only to, or are exclusively within the custody or control of, the
`Company and the Individual Defendants. Plaintiff believes that substantial additional evidentiary
`support will exist for the allegations set forth herein after a reasonable opportunity for discovery.
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`NATURE OF THE ACTION
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`This is a federal securities class action on behalf of a class consisting of all persons
`1.
`other than Defendants who purchased or otherwise acquired common shares of Pinterest stock
`between May 16, 2019 and November 1, 2019, both dates inclusive (the “Class Period”), seeking to
`recover damages caused by Defendants’ violation of the federal securities laws and to pursue
`remedies under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange
`Act”) and Rule 10b-5 promulgated thereunder, against the Company and certain of its top officials.
`Pinterest is a Delaware corporation headquartered in San Francisco, California. The
`2.
`Company is an image sharing and social media service comprised of small images or “pins” for
`finding ideas like recipes, home décor and style inspiration. The Company offers online marketing
`services to commercial brands, which allow them to connect with people on the basis of their shared
`tastes, aesthetic preferences and interests. Pinterest monetizes its platform through online
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 3 of 21
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`advertising. The Company utilizes user data to show targeted advertisements to its users based on
`their interests and searches. As far as advertising revenue is concerned, the Company readily admits
`that its financial and operational well-being critically depends on its ability to grow its base of
`monthly active users.
`Throughout the Class Period, Defendants repeatedly assured the market that Pinterest
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`was successfully expanding its domestic user base and that there existed a significant addressable
`market of U.S. users that served as a catalyst for its online advertising revenue. Unbeknownst to
`investors, however, the domestic market was quickly becoming saturated, leaving little room for
`future expansion or growth. This negative trend, which would ultimately impact Pinterest’s current
`and future financial results, was known to Defendants throughout the Class Period, yet undisclosed
`to the investing public.
`Therefore, throughout the Class Period, Defendants made materially false and
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`misleading statements, and failed to disclose material adverse facts about the Company’s business,
`operations, and financial health. Specifically, Defendants made false and/or misleading statements
`and failed to disclose to investors that: (i) the Company’s addressable market in the U.S. was reaching
`its maximum capacity; (ii) which significantly decelerated Pinterest’s future ability to monetize on
`U.S. average revenue per user; (iii) Pinterest was at an increased risk of losing advertising revenue;
`(iv) and as a result, Defendants’ public statements were materially false and misleading at all relevant
`times or lacked a reasonable basis and omitted material facts.
`On October 31, 2019, Pinterest announced disappointing preliminary financial results
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`for the third quarter 2019, having missed revenue estimates. Additionally, Pinterest reported net
`revenue $279.7 versus the consensus projection of $282 million, indicating strong deceleration in the
`growth of its domestic user base. The Company also gave full year 2019 guidance, which it only
`marginally increased, indicating further deceleration in future quarters.
`On this news, the price of Pinterest common shares sharply declined by 17%, to close
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`at $20.86, on November 1, 2019, on unusually high trading volume.
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 4 of 21
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`As a result of Pinterest’s wrongful acts and misrepresentations, and the precipitous
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`decline in the market value of its common shares, Plaintiff and other Class members have suffered
`significant losses and damages.
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`JURISDICTION AND VENUE
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`The claims asserted herein arise under Section 10(b) and 20(a) of the Exchange Act
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`(15 U.S.C. § 78j(b) and 78t(a)) and Rule 10b-5 promulgated thereunder by the SEC (17 C.F.R. §
`240.10b-5).
`This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C.
`9.
`§ 1331 and Section 27 of the Exchange Act.
`Venue is proper in this judicial district pursuant to Section 27 of the Exchange Act
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`(15 U.S.C. § 78aa) and 28 U.S.C. § 1391(b). Pinterest’s common stock trades on the New York Stock
`Exchange (“NYSE”). Accordingly, there are presumably hundreds, if not thousands, of investors in
`Pinterest’s common stock located within the U.S., some of whom undoubtedly reside in this judicial
`district.
`In connection with the acts alleged in this Complaint, Pinterest, directly or indirectly,
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`used the instrumentalities of interstate commerce, including interstate wires, U.S. Postal Service
`mail, wireless spectrum, and the national securities exchange.
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`INTRADISTRICT ASSIGNMENT
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`Pursuant to Local Rule 3-2(c), this is a securities fraud class action to be assigned on
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`a district-wide basis. Defendant Pinterest, Inc. is headquartered in San Francisco, CA, which is
`within the San Francisco/Oakland Division.
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`PARTIES
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`Plaintiff is a resident of Smithsburg, Maryland. As set forth in the attached
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`Certification, incorporated by reference herein, Plaintiff acquired Pinterest’s shares during the Class
`Period and was damaged by the federal securities law violations and false and/or misleading
`statements and/or material omissions alleged herein.
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 5 of 21
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`Defendant Pinterest is a Delaware company with a principal place of business at 505
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`Brannan Street, San Francisco, California, United States. Pinterest shares trade on the NYSE under
`the ticker symbol “PINS.” Defendant Pinterest is a visual discovery platform where users create,
`share and discover image-based content for inspiration for their lives.
`Defendant Ben Silbermann (“Defendant Silbermann”), is the co-founder of the
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`Company and has served as the Company’s CEO since the launch of the Company in January 2010.
`Defendant Todd Morgenfeld (“Defendant Morgenfeld”), has served as the
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`Company’s CFO since October 2016.
`The Individual Defendants possessed the authority to control the contents of
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`statements made by Pinterest in the Company’s reports to the SEC, press releases and presentations
`to securities analysts, money and portfolio managers and institutional investors, i.e., the market. The
`Individual Defendants were provided with copies of the Company’s reports and press releases alleged
`herein to be misleading prior to, or shortly after, their issuance and had the ability and opportunity to
`prevent their issuance or cause them to be corrected. Due to their position with the Company at
`various points, and their access to Pinterest’s material information that was unavailable to the public,
`the Individual Defendants knew that the adverse facts described herein were not disclosed to and
`were being concealed from investors. Defendants are therefore liable for the false statements and
`omissions alleged herein.
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`SUBSTANTIVE ALLEGATIONS
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`Background
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`Launched in 2010, Pinterest is a visual search engine, where users create, share and
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`seek inspiration from content in various categories such as home décor, recipes, and fashion. On both
`its website and app, Pinterest consists of images called “pins” that have been linked to or from a
`website or uploaded by a user. These pins are then grouped in themes called “boards” to create
`different virtual albums. The Company caters to many business enterprises that utilize Pinterest to
`promote their businesses and websites and to attract buyers. The Company filed its Initial Public
`Offering on March 22, 2019 and started trading publicly on April 18, 2019.
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 6 of 21
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`At the time of its Initial Public Offering, Pinterest had more than 250 million monthly
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`active users, two thirds of whom are females. Of Pinterest’s female users, the majority are moms,
`who according to marketing studies, are often the primary decision makers when it comes to buying
`products and services for their households. As such, Pinterest’s audience is highly valuable to online
`advertisers.
`Pinterest’s primary source of revenue is advertising revenue. Pinterest sells targeted
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`ads, called “promoted pins,” that appear at the top of users’ feeds and search results. Promoted Pins
`are effectively advertisements, paid for by a variety of commercial entities. Pinterest utilizes user
`data to target advertisements based on user interests and searches, as well as other demographics.
`Since Pinterest’s revenue is driven by interest and use of its platform, Pinterest’s ability to generate
`revenue is critically dependent on the size and demographics of its active user base and its ability to
`attract and grow its user audience.
`Pinterest measures the monetization of its platform through Average Revenue per
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`User (“ARPU”), which is the total revenue in a given geography during a period divided by the
`average of the number of monthly active users (“MAUs”) in that geography. ARPU generated by
`international users is significantly lower than revenue generated by U.S. users. For example, during
`the year ended December 31, 2018, U.S. ARPU was $9.04 per user while international ARPU was
`miniscule by comparison, at just $0.25 per user. The difference between international and domestic
`ARPU is largely driven by the relative size and maturity of the U.S. digital advertising market. As a
`result, Pinterest’s ability to grow its domestic active user base is of great importance to its overall
`ability to generate revenue and is a critically important metric for the market.
`Immediately after going public, the Company embarked on an aggressive campaign
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`to convince investors of its future growth and monetization opportunities. During the months
`following its March 2019 IPO, the Individual Defendants, time and again, misrepresented to the
`investing public the market opportunities that purportedly existed that would allow Pinterest to grow
`and scale its business on the domestic market. For example, Pinterest assured investors of
`“comfortable room” for growth of its MAUs in both, international and domestic markets, as well as
`the “strong trends in U.S. [ARPU].” What Pinterest knew – but failed to relay to the investing public
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 7 of 21
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`— was that the domestic market was quickly becoming fully saturated and was approaching its
`maximum capacity, rendering Pinterest’s path to future growth less than certain. These false
`assurances and omissions gave the investing public no reason to suspect that Pinterest’s business was
`about to max out its domestic active user potential, and thereby significantly decelerate its revenue
`growth.
`Throughout the Class Period, Defendants made materially false and misleading
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`statements, and failed to disclose material adverse facts about the Company’s business, operations,
`and financial health. Specifically, Defendants made false and/or misleading statements and failed to
`disclose to investors that: (i) the Company’s addressable market in the U.S. was reaching its
`maximum capacity; (ii) which significantly decelerated Pinterest’s future ability to monetize on U.S.
`ARPU; (iii) Pinterest was at an increased risk of losing advertising revenue; (iv) and as a result,
`Defendants’ public statements were materially false and misleading at all relevant times or lacked a
`reasonable basis and omitted material facts.
`Materially False And Misleading Statements
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`The Class Period begins on May 16, 2019. On that day, Pinterest issued a press release
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`announcing its financial results for the first quarter of 2019. In the press release, Defendant
`Morgenfeld touted the Company’s revenue growth, particularly highlighting revenue generated from
`domestic users: “We were particularly encouraged by the strength we saw in U.S. revenue and
`international user growth.”
`In the Company’s quarterly report filed on May 17, 2019 on SEC Form 10-Q (“Q1
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`2019 Report”), the Company reported reaching 291 million MAUs, representing a 22% year-over-
`year growth. As to the revenue generated from MAUs, the Company highlighted the U.S. revenue
`growth, a critical metric of Pinterest’s financial and operational well-being, stating as follows:
`Revenue based on the geographic location of our users increased by
`51% in the United States to $187.0 million and by 107%
`internationally to $14.9 million. U.S. revenue growth was driven by
`a 7% increase in average U.S. MAUs and a 41% increase in U.S.
`ARPU. International revenue growth was driven by a 30% increase
`in average international MAUs and a 59% increase in international
`ARPU. ARPU growth in the U.S. and internationally was driven by
`higher monetization of both of those user bases largely due to an
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 8 of 21
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`increase in the number of advertisements delivered as a result of an
`increase in the overall number of advertisers on our platform and
`increased demand from existing advertisers.
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`The Company’s Q1 2019 Report further informed that the Company’s “revenue in the
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`United States is higher primarily due to our decision to focus our earliest monetization efforts there
`and also due to the relative size and maturity of the U.S. digital advertising market.” Appended as
`exhibits to the Q1 2019 Report were signed certifications pursuant to the Sarbanes-Oxley Act of
`2002, wherein the Individual Defendants certified that “[t]he [Q1 2019 Report] fully complies with
`the requirements of section 13(a) or 15(d) of the Securities Exchange Act of 1934,” and that “[t]he
`information contained in the [Q1 2019 Report] fairly presents, in all material respects, the financial
`condition and results of operations of the Company.”
`In a letter to shareholders dated May 16, 2019, the Company provided shareholders
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`with an unrealistic outlook on its future U.S. revenue, assuring investors of the continued growth in
`both the U.S. and international markets:
`We expect to maintain strong momentum in our business as we
`achieve larger scale. We expect revenue to grow 40%-43% compared
`to full-year 2018, driven by improving ARPU, particularly in the
`U.S. We expect to grow users in both the U.S. and International.”
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`During the Q1 2019 Earnings Call held on the same day to discuss the Company’s
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`financial results and operations, Defendant Morgenfeld similarly assured investors that the U.S.
`market would continue to grow, stating: “[We] see comfortable room in all of our markets, in
`particular in international markets but also in the US, to continue to drive advertising content higher.”
`When asked about the number of advertisers Pinterest had during the first quarter of 2019, Defendant
`Morgenfeld supported his prior statement and confirmed that the number of advertisers was growing
`and that the trend was expected to continue.
`On August 1, 2019, the Company issued a press release, announcing its financial
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`results for the second quarter of 2019. In the press release, Defendant Silbermann highlighted the
`Company’s growth and diversification of its advertiser base. Defendant Morgenfeld echoed
`Defendant Silbermann’s unrealistic enthusiasm, stating that “[t]he momentum we have seen over the
`past several quarters continued as more advertisers recognize the power of our platform to reach
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 9 of 21
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`consumers.” As to the U.S. revenue, Defendant Morgenfeld stated the Company “remain[s]
`encouraged by trends in U.S. ARPU and by user growth in international markets.”
`In a letter to shareholders dated August 1, 2019, the Company further touted its
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`growing MAU, and once again, highlighted the “strong trends in U.S. average revenue per user
`(ARPU) and user growth in international markets.” Additionally, the Company highlighted the
`accelerated U.S. revenue, stating that the U.S. ARPU increased “41% year-over-year.” As to
`guidance for 2019, the Company provided unrealistic expectations, stating as follows:
`We expect revenue to grow 45-48% in 2019 compared to full-year
`2018, driven by improving ARPU, particularly in the U.S. We
`expect to grow users in both the U.S. and international. Consistent
`with trends in recent years, we expect to grow International users at
`a faster pace relative to the U.S.
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`That same day, on the Q2 2019 Earnings Call, the Individual Defendants discussed
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`the Company’s financial results and operations. During the call, the Individual Defendants continued
`to exaggerate the forecast for Pinterest shares and their expectation of Pinterest’s continued growth.
`More specifically, during the Q2 2019 Earnings Call, Defendant Silbermann touted Pinterest’s 62%
`growth year-over-year and Pinterest’s attainment of “more than 300 million people now using
`Pinterest every month.” As to Pinterest’s growing advertiser base, Defendant Morgenfeld echoed
`these rosy predictions:
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`[W]e continue to accelerate the growth in the number of advertisers
`on the platform. We talked last quarter about having done that and
`we accelerated yet again in the number of advertisers this quarter as
`well.
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`*
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`Longer term, we would expect price to continue to improve because
`advertisers tell us that they’re getting a great return from their
`investment on Pinterest. So today the exercise is trying to get as
`many advertisers on the platform. So that they all see the value and
`help us build a lot more robust auction.
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`In the quarterly report for the second quarter 2019 filed on August 2, 2019 on SEC
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`Form 10-Q (“Q2 2019 Report”), the Company reiterated reaching U.S. ARPU of $2.80, which
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 10 of 21
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`represented growth of 41%, compared to the three months ended June 30, 2018. As to the revenue
`generated from domestic and international users, the Company stated:
`For the three and six months ended June 30, 2019, U.S. revenue
`growth was driven by 41% and 39% respective increases in U.S.
`ARPU supported by a 13% increase in U.S. MAUs, and
`international revenue growth was driven by 123% and 89%
`respective increases in international ARPU supported by a 38%
`increase in international MAUs. ARPU growth in the U.S. and
`internationally was driven by higher monetization of both of those
`user bases largely due to an increase in advertising demand from
`new and existing advertisers on our platform. This resulted in an
`increase in the number of advertisements served as well as an
`increase in the price of advertisements, but the impact of the latter
`was not significant.
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`Appended as exhibits to the Q2 2019 Report were signed certifications pursuant to
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`the Sarbanes-Oxley Act of 2002, wherein the Individual Defendants certified that “[t]he [Q2 2019
`Report] fully complies with the requirements of section 13(a) or 15(d) of the Securities Exchange
`Act of 1934,” and that “[t]he information contained in the [Q2 2019 Report] fairly presents, in all
`material respects, the financial condition and result of operations of the Company.”
`The above statements identified in ¶¶ 24 - 33 were materially false and/or misleading
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`and failed to disclose material facts about the Company’s business, operations, and financial health.
`Specifically, Defendants made false and/or misleading statements and failed to disclose to investors
`that: (i) the Company’s addressable market in the U.S. was reaching its maximum capacity; (ii) which
`significantly decelerated Pinterest’s future ability to monetize on U.S. ARPU; (iii) Pinterest was at
`an increased risk of losing advertising revenue; (iv) and as a result, Defendants’ public statements
`were materially false and misleading at all relevant times or lacked a reasonable basis and omitted
`material facts.
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`The Truth Emerges
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`On October 31, 2019, Pinterest announced its financial results for the quarter ended
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`September 30, 2019. In a letter to shareholders, which was attached as exhibit 99.1. to the Form 8-
`K filed with the SEC on the same day, Pinterest provided highlights of its financial results, including
`its overall Q3 2019 revenue growth. Despite the Individual Defendants’ rosy projections over the
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`Case 3:20-cv-08243-WHO Document 1 Filed 11/23/20 Page 11 of 21
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`course of several months, the Company reported disappointing financial results, including 8% growth
`in U.S. MAUs year-over-year, which reached 87 million, only 8 million more than the same period
`of the previous year. Critically, the 8% growth represented a 6 point deceleration from the previous
`quarter and a 2 point deceleration on a 2-year basis. Pinterest thereby solidly missed the Street’s
`revenue target and materially missed the most critical metric of its performance — revenue derived
`from US advertising. Pinterest reported its total Q3 2019 revenue at $279.7 million as compared to
`the consensus projection of $282 million, and its U.S. advertising revenue at $251 million as
`compared to buy-side expectations of $265 million. As to full year 2019 guidance, the Company
`only marginally increased its guidance, implying further deceleration in future quarters.
`On this news, the price of the Company’s shares steeply declined by 17%, to close at
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`$20.86, on November 1, 2019, on unusually high trading volume.
`Pinterest’s announcement came as a great surprise to the investing public and the
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`analysts alike who were shocked by the sudden and disappointing news. During an Earnings Call
`held on November 1, 2019, Individual Defendants attempted to soften the impact of the disappointing
`news by highlighting the Company’s overall user growth expansion. For example, when pressed by
`analyst Mark Mahaney of RBC to talk about the “notable deceleration” in U.S. ARPU and its growth
`trajectory, Defendant Morgenfeld deflected the question, instead pointing to Pinterest’s 47% overall
`growth, and focusing on the Company’s future growth:
`And so as we think about growth going forward, it’s really going to
`stem, especially in the US, around two new product areas that have
`been -- we've been focused on now and talked about for some time,
`but will scale going forward. They will drive advertiser
`diversification, and those two areas are shopping and SMB.
`
`38. When asked by Justin Post of Bank of America to provide more detail regarding the
`Company’s guidance for full year 2019, which suggested more deceleration in Q4, Defendant
`Morgenfeld likewise dodged the question, stating:
`I go back to the fundamental principle here is that we’re investing
`in a bunch of new things around advertiser diversification that I
`think will bear fruit over the coming several quarters and years.
`Those are principally around international coverage and around our
`
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`mid-market and SMB presence, which I’m delighted with the
`progress we’re making, but it’s just going to be a journey.
`
`Following this news, several analysts lowered Pinterest’s price target and issued
`39.
`reports pointing to the surprising news delivered by Pinterest on Halloween. For example, Pivotal
`Research Group issued a report titled “We were wrong – not the ‘Treat’ we were hoping to see,” in
`which it observed that the “deceleration in the US advertising was far more than we had hoped for,”
`and added “we got this one DEAD wrong.” (caps in original). Pivotal Research Group subsequently
`lowered Pinterest’s price target by over 25% from $32 to $23.5. Similarly, a Deutsche Bank report
`titled “No candy at this house tonight” called Pinterest’s U.S. user growth “uninspiring” and was
`critical of the Company’s international rollout, stating “[Pinterest] clearly needs more feet on the
`street to move the needle on revenue and here the company is moving more slowly.” Deutsche Bank
`subsequently lowered its price target by more than 15% from $39 to $32.
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`CLASS ACTION ALLEGATIONS
`
`Plaintiff brings this action pursuant to Rules 23(a) and (b) of the Federal Rules of
`40.
`Civil Procedure, on its own behalf and as representative of a Class, consisting of all those who
`purchased or otherwise acquired Pinterest’s shares during the Class Period (“Class”); and were
`damaged upon the revelation of the alleged corrective disclosures. Excluded from the Class are
`Defendants, the officers and directors of the Company, at all relevant times, members of their
`immediate families and their legal representatives, heirs, successors or assigns and any entity in
`which Defendants Silbermann or Morgenfeld have or had a controlling interest.
`The Class is so numerous and geographically dispersed that joinder of all members is
`41.
`impracticable. Throughout the Class Period, Pinterest’s shares were actively traded on the NYSE.
`While the exact number of Class members is unknown to Plaintiff at this time and can be ascertained
`only through appropriate discovery, Plaintiff believes that there are hundreds or thousands of
`members in the proposed Class. Record owners and other members of the Class may be readily
`identifiable from information and records in the possession of Defendants or its transfer agent and
`may be notified of the pendency of this action by mail, using the form of notice similar to that
`customarily used in securities class actions.
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`Plaintiff’s claims are typical of the claims of the other members of the Class.
`42.
`Plaintiff and members of the Class sustained damages from the same wrongful conduct of
`Defendants. The injuries and damages of each member of the Class were directly caused by
`Defendants’ wrongful conduct in violation of the laws described herein.
`Plaintiff will fairly and adequately protect and represent the interests of members of
`43.
`the Class. Plaintiff is an adequate representative of the Class and has no interest which is adverse to
`the interests of absent Class members. Plaintiff has retained counsel competent and experienced in
`class action litigation, including class actions in the financial services industry.
`Common questions of law and fact exist as to all members of the Class, which
`44.
`predominate over questions affecting solely individual members of the Class. These common
`questions of law include, without limitation:
`• whether statements made by Pinterest and the Individual Defendants to investors
`during the Class Period included misrepresentations of material facts about the growth
`and revenue prospects, financial condition, operations and oversight of operations at
`Pinterest;
`
`• whether Pinterest failed to indicate to its investors that the Company’s international
`MAU growth does not account for the Company’s majority of revenue and the slow-
`down in the U.S. growth adversely affects the advertising on the platform;
`
`• whether Pinterest and the Individual Defendants acted knowingly or recklessly in
`issuing false and misleading statements or omitting material information that would
`correct the misstatements;
`
`• whether Pinterest’s and the Individual Defendants’ acts as alleged herein constituted
`violations of the federal securities laws;
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`• whether the prices of Pinterest’s shares during the Class Period were impacted by the
`Company’s and the Individual Defendants’ conduct described herein;
`
`•
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`•
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`injury suffered by Plaintiff and Class members; and
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`the appropriate measure of damages suffered by Plaintiff and Class members.
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`A class action is superior to other methods for the fair and efficient adjudication of
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`the controversy because joinder of all Class members is impracticable. Treatment as a class will
`permit a large number of similarly situated persons to prosecute their common claims in a single
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`CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL
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