19.  Symantec Corporation provides security, storage, and systems management solutions to  help businesses and consumers secure and manage their information. The Company offers software and  services that protect, manage, and control information risks related to security, data protection, storage,  compliance, and management.  Materially False and Misleading Statements Issued During the Class Period   21.  The 2017 10-K stated in relevant part:  Our management has concluded that, as of March 31, 2017, our internal control  over financial reporting was effective at the reasonable assurance level based on  these criteria.  The Company’s independent registered public accounting firm has issued an  attestation report regarding its assessment of the Company’s internal control over  financial reporting as of March 31, 2017, which is included in Part IV, Item 15 of  this annual report.  c) Changes in Internal Control over Financial Reporting  There were no changes in our internal control over financial reporting during the  quarter ended March 31, 2017, that have materially affected, or are reasonably  likely to materially affect, our internal control over financial reporting.   22.  On August 4, 2017, Symantec filed a Quarterly Report on Form 10-Q with the SEC,  announcing the Company’s financial and operating results for the quarter ended June 30, 2017 (“Q1  2018 10-Q”).  The Q1 2018 10-Q was signed by Defendants Clark and Noviello.  The Q1 2018 10-Q  contained signed certifications pursuant to SOX by Defendants Clark and Noviello attesting to the  accuracy of financial reporting, the disclosure of any material changes to the Company’s internal  control over financial reporting and the disclosure of all fraud.   24.  On August 16, 2017, the Company filed a Schedule 14A with the SEC (the “2017 Proxy  Statement”), which set forth the Company’s Executive Compensation practices and philosophy. The  2017 Proxy Statement stated that the Company’s Executive Compensation programs provide “direct  alignment with stockholders” and that the Company uses “responsible pay policies to reinforce strong  governance and enhance stockholder alignment.” The 2017 Proxy Statement discussion of executive  compensation states, in relevant part:  36.  Plaintiff brings this action as a class action pursuant to Federal Rule of Civil Procedure  23(a) and (b)(3) on behalf of a Class, consisting of all those who purchased or otherwise acquired  Symantec securities traded on the NASDAQ during the Class Period (the “Class”); and were damaged  upon the revelation of the alleged corrective disclosures. Excluded from the Class are Defendants  herein, 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  have or had a controlling interest.   38.  Plaintiff’s claims are typical of the claims of the members of the Class as all members of  the Class are similarly affected by Defendants’ wrongful conduct in violation of federal law that is  complained of herein.   39.  Plaintiff will fairly and adequately protect the interests of the members of the Class and  has retained counsel competent and experienced in class and securities litigation. Plaintiff has no  interests antagonistic to or in conflict with those of the Class.   40.  Common questions of law and fact exist as to all members of the Class and predominate  over any questions solely affecting individual members of the Class. Among the questions of law and  fact common to the Class are:    whether the federal securities laws were violated by Defendants’ acts as alleged  herein;    whether statements made by Defendants to the investing public during the Class  Period misrepresented material facts about the financial condition, business,  operations, and management of Symantec;    whether Defendants caused Symantec to issue false and misleading financial  statements during the Class Period;    whether Defendants acted knowingly or recklessly in issuing false and  misleading financial statements;    whether the prices of Symantec securities during the Class Period were  artificially inflated because of Defendants’ conduct complained of herein; and    whether the members of the Class have sustained damages and, if so, what is the  proper measure of damages.   42.  Plaintiff will rely, in part, upon the presumption of reliance established by the fraud-on- the-market doctrine in that:    Defendants made public misrepresentations or failed to disclose material facts  during the Class Period;    the omissions and misrepresentations were material;    Symantec securities are traded in efficient markets;    the Company’s shares were liquid and traded with moderate to heavy volume  during the Class Period;    the Company traded on the NASDAQ, and was covered by multiple analysts;    the misrepresentations and omissions alleged would tend to induce a reasonable  investor to misjudge the value of the Company’s securities; and    Plaintiff and members of the Class purchased and/or sold Symantec securities  between the time the Defendants failed to disclose or misrepresented material  facts and the time the true facts were disclosed, without knowledge of the  omitted or misrepresented facts.   43.  Based upon the foregoing, Plaintiff and the members of the Class are entitled to a  presumption of reliance upon the integrity of the market.   44.  Alternatively, Plaintiff and the members of the Class are entitled to the presumption of  reliance established by the Supreme Court in Affiliated Ute Citizens of the State of Utah v. United  States, 406 U.S. 128, 92 S. Ct. 2430 (1972), as Defendants omitted material information in their Class  Period statements in violation of a duty to disclose such information, as detailed above.  45.  Plaintiff repeats and realleges each and every allegation contained above as if fully set  forth herein.   46.  This Count is asserted against Symantec and the Individual Defendants and is based  upon Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5 promulgated thereunder  by the SEC.   47.  During the Class Period, Symantec and the Individual Defendants, individually and in  concert, directly or indirectly, disseminated or approved the false statements specified above, which  they knew or deliberately disregarded were misleading in that they contained misrepresentations and  failed to disclose material facts necessary in order to make the statements made, in light of the  circumstances under which they were made, not misleading.   48.  Symantec and the Individual Defendants violated §10(b) of the 1934 Act and Rule 10b-5  in that they:    employed devices, schemes and artifices to defraud;    made untrue statements of material facts or omitted to state material facts  necessary in order to make the statements made, in light of the circumstances  under which they were made, not misleading; or    engaged in acts, practices and a course of business that operated as a fraud or  deceit upon plaintiff and others similarly situated in connection with their  purchases of Symantec securities during the Class Period.   50.  Individual Defendants, who are the senior officers and/or directors of the Company, had  actual knowledge of the material omissions and/or the falsity of the material statements set forth above,  and intended to deceive Plaintiff and the other members of the Class, or, in the alternative, acted with  reckless disregard for the truth when they failed to ascertain and disclose the true facts in the statements  made by them or other Symantec personnel to members of the investing public, including Plaintiff and  the Class.   51.  As a result of the foregoing, the market price of Symantec securities was artificially  inflated during the Class Period.  In ignorance of the falsity of Symantec’s and the Individual  Defendants’ statements, Plaintiff and the other members of the Class relied on the statements described  above and/or the integrity of the market price of Symantec securities during the Class Period in  purchasing Symantec securities at prices that were artificially inflated as a result of Symantec’s and the  Individual Defendants’ false and misleading statements.   52.  Had Plaintiff and the other members of the Class been aware that the market price of  Symantec securities had been artificially and falsely inflated by Symantec’s and the Individual  Defendants’ misleading statements and by the material adverse information which Symantec’s and the  Individual Defendants did not disclose, they would not have purchased Symantec’s securities at the  artificially inflated prices that they did, or at all.   53.  As a result of the wrongful conduct alleged herein, Plaintiff and other members of the  Class have suffered damages in an amount to be established at trial.   55.  Plaintiff repeats and realleges each and every allegation contained in the foregoing  paragraphs as if fully set forth herein.   56.  During the Class Period, the Individual Defendants participated in the operation and  management of Symantec, and conducted and participated, directly and indirectly, in the conduct of  Symantec’s business affairs. Because of their senior positions, they knew the adverse non-public  information regarding the Company’s inadequate internal safeguards in data security protocols.   57.  As officers and/or directors of a publicly owned company, the Individual Defendants had  a duty to disseminate accurate and truthful information with respect to Symantec’s financial condition  and results of operations, and to correct promptly any public statements issued by Symantec which had  become materially false or misleading.   59.  By reason of the above conduct, the Individual Defendants are liable pursuant to Section  20(a) of the Exchange Act for the violations committed by Symantec.  Background   Violation of Section 20(a) of The Exchange Act  Against The Individual Defendants  