18.  On July 26, 2016, the Company filed a Form 10-Q for the quarter ended June 30,  2016 (the “2Q 2016 10-Q”) with the SEC, which provided the Company’s second quarter 2016  financial results and position. The 2Q 2016 10-Q stated that the Company’s disclosure controls  and procedures were effective as of June 30, 2016, and that “[t]here have been no changes in  PMI’s internal control over financial reporting during the most recent fiscal quarter that have  materially affected, or are reasonably likely to materially affect, PMI’s internal control over  financial reporting.” The 2Q 2016 10-Q was signed by Defendant Olczak. The 2Q 2016 10-Q  contained signed certifications pursuant to the Sarbanes-Oxley Act of 2002 (“SOX”) by  Defendants Calantzopoulos and Olczak 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.   22.  The statements referenced in ¶¶18-21 above were materially false and/or  misleading because they misrepresented and failed to disclose the following adverse facts  pertaining to the Company’s business, operational and financial results, which were known to  Defendants or recklessly disregarded by them. Specifically, Defendants made false and/or  misleading statements and/or failed to disclose that: (1) there were irregularities in the clinical  experiments that underpin Philip Morris’ application to the FDA for approval of its iQOS  smoking device; and (2) as a result, Defendants’ statements about the Company’s business,  operations and prospects were materially false and misleading and/or lacked a reasonable bases  at all relevant times.   The Truth Emerges   23.  On December 20, 2017, Reuters published a report stating that “[f]ormer  employees and contractors [of Phillip Morris] have detailed irregularities in the clinical  experiments that underpin Philip Morris International’s application to the FDA for approval of  its iQOS smoking device,” stating in pertinent part:  30.  The members of the Class are so numerous that joinder of all members is  impracticable. Throughout the Class Period, the Company’s 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  or thousands of members in the proposed Class. Record owners and other members of the Class  may be identified from records maintained by the Company 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.   31.  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.   32.  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.   34.  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.   36.  Based upon the foregoing, Plaintiff and the members of the Class are entitled to a  presumption of reliance upon the integrity of the market.   37.  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.  39.  This Count is asserted against the Company 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.   40.   During the Class Period, the Company 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.   41.  The Company 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 the Company’s  securities during the Class Period.   43.  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 personnel of the Company to  members of the investing public, including Plaintiff and the Class.   44.  As a result of the foregoing, the market price of the Company’s securities were  artificially inflated during the Class Period. In ignorance of the falsity of the Company’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 the Company’s securities  during the Class Period in purchasing the Company’s securities at prices that were artificially  inflated as a result of the Company’s and the Individual Defendants’ false and misleading  statements.   45.  Had Plaintiff and the other members of the Class been aware that the market price  of the Company’s securities had been artificially and falsely inflated by the Company’s and the  Individual Defendants’ misleading statements and by the material adverse information which the  Company and the Individual Defendants did not disclose, they would not have purchased the  Company’s securities at the artificially inflated prices that they did, or at all.   47.  By reason of the foregoing, the Company and the Individual 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 purchases of the Company’s securities during the Class Period.  48.  Plaintiff repeats and realleges each and every allegation contained in the  foregoing paragraphs as if fully set forth herein.   49.  During the Class Period, the Individual Defendants participated in the operation  and management of the Company, and conducted and participated, directly and indirectly, in the  conduct of the Company’s business affairs. Because of their senior positions, they knew the  adverse non-public information regarding the Company’s business practices.   50.  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 the  Company’s financial condition and results of operations, and to correct promptly any public  statements issued by the Company which had become materially false or misleading.   52.  Each of the Individual Defendants, therefore, acted as a controlling person of the  Company. By reason of their senior management positions and/or being directors of the  Company, each of the Individual Defendants had the power to direct the actions of, and  exercised the same to cause, the Company to engage in the unlawful acts and conduct  complained of herein. Each of the Individual Defendants exercised control over the general  operations of the Company and possessed the power to control the specific activities which  comprise the primary violations about which Plaintiff and the other members of the Class  complaint.   53.  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 the Company.  Violation of Section 10(b) of The Exchange Act and Rule 10b-5  Against All Defendants   Violation of Section 20(a) of The Exchange Act  Against The Individual Defendants   