17.  Nokia is a network and technology company that provides hardware, software,  and services for telecommunications operators and enterprises and provides fixed networking  solutions.      18.  In November 2016, Nokia closed its acquisition of Alcatel-Lucent, a company  that offers fixed, IP, optical applications and analytics technologies. Nokia and Alcatel-Lucent  have been operating as a combined company since January 2016.   Materially False and Misleading  Statements Issued During the Class Period   24.  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 and entities that  purchased or otherwise acquired Nokia securities between October 25, 2018 and March 21,  2019, inclusive, and who were damaged thereby (the “Class”). 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 have or had a controlling interest.   35.  As alleged herein, Defendants acted with scienter since Defendants knew that the  public documents and statements issued or disseminated in the name of the Company were  materially false and/or 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  federal securities laws.  As set forth elsewhere herein in detail, the Individual Defendants, by  virtue of their receipt of information reflecting the true facts regarding Nokia, their control over,  and/or receipt and/or modification of Nokia’s allegedly materially misleading misstatements  and/or their associations with the Company which made them privy to confidential proprietary  information concerning Nokia, participated in the fraudulent scheme alleged herein.   42.  Plaintiff repeats and re-alleges each and every allegation contained above as if  fully set forth herein.    53.  Plaintiff repeats and re-alleges each and every allegation contained above as if  fully set forth herein.    54.  Individual Defendants acted as controlling persons of Nokia within the meaning  of Section 20(a) of the Exchange Act as alleged herein. By virtue of their high-level positions  and their ownership and contractual rights, participation in, and/or awareness of the Company’s  operations and intimate knowledge of the false financial statements filed by the Company with  the SEC and disseminated to the investing public, Individual Defendants had the power to  influence and control and did influence and control, directly or indirectly, the decision-making of  the Company, including the content and dissemination of the various statements which Plaintiff  contends are false and misleading. Individual Defendants were provided with or had unlimited  access to copies of the Company’s reports, press releases, public filings, and other statements  alleged by Plaintiff to be misleading prior to and/or shortly after these statements were issued  and had the ability to prevent the issuance of the statements or cause the statements to be  corrected.    Background   Violation of Section 20(a) of The Exchange Act   Against the Individual Defendants   Violation of Section 10(b) of The Exchange Act and   Rule 10b-5 Promulgated Thereunder   Against All Defendants  