15.  On July 7, 2018, Infosys filed its annual report on Form 20-F for the fiscal year  ended March 31, 2018 with the SEC (the “2018 20-F”). The 2018 20-F contained signed  certifications pursuant to the Sarbanes-Oxley Act of 2002 (“SOX”) signed by Defendants Parekh  and Ranganath attesting to the accuracy of financial reporting, the disclosure of any material  changes to the Company’s internal controls over financial reporting, and the disclosure of all fraud.     16.  The 2018 20-F stated that Infosys’s Board “on January 12, 2018 adopted the revised  Code of Conduct and Ethics which is applicable to all officers, directors and employees and is  posted on our website at www.infosys.com. The Code of Conduct and Ethics is filed as an exhibit  to this Annual Report on Form 20-F.” The Code of Conduct and Ethics stated the following  regarding records and disclosures, in pertinent part:   The integrity of our financial transactions and records is critical to the operation of  our business. Our shareholders’ trust is based on their confidence in the accurate  recording of our financial transactions. Additionally, as a listed company, we are  bound by certain standards for accurate financial reporting and we are required to  have appropriate internal controls and procedures. If you have responsibility for or  5  any involvement in financial reporting or accounting, you should have an  appropriate understanding of, and you should seek in good faith to adhere to,  relevant accounting and financial reporting principles, standards, laws, rules and  regulations and the company’s financial and accounting policies, controls and  procedures. If you are a senior officer, you should seek to ensure that the internal  controls and procedures in your business area are in place, understood and  followed.  *  *  *  Infosys is committed to provide full, fair, accurate, timely and clear disclosures in  reports and documents that we file with, or submit to our regulators and in our other  public communications. To enable this, we must ensure that we comply with our  disclosure controls and procedures, and our internal control over financial  reporting.  28.  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 persons other than Defendants  who acquired Infosys securities publicly traded on the NYSE during the Class Period, and who  were damaged thereby (the “Class”). Excluded from the Class are Defendants, the officers and  directors of Infosys, members of the Individual Defendants’ immediate families and their legal  representatives, heirs, successors or assigns and any entity in which Officer or Director  Defendants have or had a controlling interest.  12   29.  The members of the Class are so numerous that joinder of all members is  impracticable. Throughout the Class Period, Infosys securities 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, if not  thousands of members in the proposed Class.   30.  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.   31.  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.   32.  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 Exchange Act 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 and business of  Infosys;  •  whether Defendants’ public statements to the investing public during the Class  Period omitted material facts necessary to make the statements made, in light of  the circumstances under which they were made, not misleading;  •  whether the Defendants caused Infosys to issue false and misleading SEC filings  during the Class Period;  13  •  whether Defendants acted knowingly or recklessly in issuing false and SEC filing  •  whether the prices of Infosys’s securities during the Class Period were artificially  inflated because of the 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.   33.  A class action is superior to all other available methods for the fair and efficient  adjudication of this controversy since joinder of all members is impracticable. Furthermore, as  the damages suffered by individual Class members may be relatively small, the expense and  burden of individual litigation make it impossible for members of the Class to individually redress  the wrongs done to them. There will be no difficulty in the management of this action as a class  action.   34.  Plaintiff will rely, in part, upon the presumption of reliance established by the  fraud-on-the-market doctrine in that:  •  Infosys ADSs met the requirements for listing, and were listed and actively traded  on the NYSE, a highly efficient and automated market;  •  As a public issuer, Infosys filed periodic public reports with the SEC;  •  Infosys regularly communicated with public investors via established market  communication mechanisms, including through the regular dissemination of press  releases via major newswire services and through other wide-ranging public  disclosures, such as communications with the financial press and other similar  reporting services; and  14  •  Infosys was followed by a number of securities analysts employed by major  brokerage firms who wrote reports that were widely distributed and publicly  available.   35.  Based on the foregoing, the market for Infosys securities promptly digested current  information regarding Infosys from all publicly available sources and reflected such information  in the prices of the ADSs, and Plaintiff and the members of the Class are entitled to a presumption  of reliance upon the integrity of the market.   36.  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 (1972), as Defendants omitted material information in their  Class Period statements in violation of a duty to disclose such information as detailed above.  37.  Plaintiff repeats and realleges each and every allegation contained above as if fully  set forth herein.   38.  This Count is asserted against Defendants 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.   39.   During the Class Period, 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.   40.  Defendants violated §10(b) of the 1934 Act and Rule 10b-5 in that they:  •  employed devices, schemes and artifices to defraud;  15  •  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 Infosys securities during the Class Period.   41.  Defendants acted with scienter in that they knew that the public documents and  statements issued or disseminated in the name of Infosys were materially false and misleading;  knew that such statements or documents would be issued or disseminated to the investing public;  and knowingly and substantially participated, or acquiesced in the issuance or dissemination of  such statements or documents as primary violations of the securities laws. These Defendants by  virtue of their receipt of information reflecting the true facts of Infosys, their control over, and/or  receipt and/or modification of Infosys’s allegedly materially misleading statements, and/or their  associations with the Company which made them privy to confidential proprietary information  concerning Infosys, participated in the fraudulent scheme alleged herein.   42.   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 Infosys personnel to members of  the investing public, including Plaintiff and the Class.   43.  As a result of the foregoing, the market price of Infosys securities was artificially  inflated during the Class Period. In ignorance of the falsity of Defendants’ statements, Plaintiff  16  and the other members of the Class relied on the statements described above and/or the integrity  of the market price of Infosys securities during the Class Period in purchasing Infosys securities  at prices that were artificially inflated as a result of Defendants’ false and misleading statements.   44.  Had Plaintiff and the other members of the Class been aware that the market price  of Infosys securities had been artificially and falsely inflated by Defendants’ misleading  statements and by the material adverse information which Defendants did not disclose, they would  not have purchased Infosys securities at the artificially inflated prices that they did, or at all.   45.   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.   46.  By reason of the foregoing, Defendants have violated Section 10(b) of the 1934  Act and Rule 10b-5 promulgated thereunder and are liable to the plaintiff and the other members  of the Class for substantial damages which they suffered in connection with their purchase of  Infosys securities during the Class Period.  47.  Plaintiff repeats and realleges each and every allegation contained in the foregoing  paragraphs as if fully set forth herein.   48.  During the Class Period, the Individual Defendants participated in the operation  and management of Infosys, and conducted and participated, directly and indirectly, in the  conduct of Infosys’s business affairs. Because of their senior positions, they knew the adverse  non-public information about Infosys’s misstatement of revenue and profit and false financial  statements.  17   49.  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 Infosys’s  financial condition and results of operations, and to correct promptly any public statements issued  by Infosys which had become materially false or misleading.   50.   Because of their positions of control and authority as senior officers, the  Individual Defendants were able to, and did, control the contents of the various reports, press  releases and public filings which Infosys’s disseminated in the marketplace during the Class  Period concerning Infosys’s results of operations. Throughout the Class Period, the Individual  Defendants exercised their power and authority to cause Infosys to engage in the wrongful acts  complained of herein. The Individual Defendants therefore, were “controlling persons” of Infosys  within the meaning of Section 20(a) of the Exchange Act. In this capacity, they participated in the  unlawful conduct alleged which artificially inflated the market price of Infosys securities.   51.  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 Infosys.  For Violations of Section 10(b) And Rule 10b-5 Promulgated Thereunder  Against All Defendants   Materially False and Misleading Statements   Violations of Section 20(a) of the Exchange Act  Against the Individual Defendants  