15. Teligent researches, develops, produces, supplies, and sells generic pharmaceutical  products.     16. On May 2, 2017, Teligent filed a Form 8-K with the SEC (the “May 2017 8-K”)  that highlighted the Company’s revenue growth in the first quarter of of 2017.  On the earnings  call following the May 2017 8-K’s release, Grenfell-Gardner stated that “[t]his growth has been  driven by a combination of new product launches and competitive supply chain dynamics to which  Teligent has been able to respond effectively.”  Then, in discussing “what comes next[,]” Grenfell- Gardner took his praise of Teligent’s supposedly well-run R&D-approval-production-launch  process one step further:  Over the coming quarter, our team is focused on delivering products in the existing  product pipeline, responding to FDA [Food and Drug Administration] and Health  Canada inquiries and preparing for the final submissions for 2017. This is the  crunch period of GDUFA [Generic Drug User Fee Amendments] Year 5 and Year  4 overlap for FDA submissions. And we are committed to upholding our  responsibilities with respect to the FDA to ensure the timely processing of our  applications.  I would point out that the two approvals that we received in this past quarter were  great examples of the benefit of this discipline. With one application approved at  18 months and the other at just over 14 months. To the extent that we can replicate  these timely approvals with our current investments in R&D, we will continue to  deliver value in the form of the return on these investments as we launch products  to the market. We have 33 ANDAs [Abbreviated New Drug Applications] on file  with the FDA today that represent a total addressable market of approximately $2  billion[.]   17. The forgoing was false and misleading because Defendants failed to disclose  product non-conformities in R&D and non-compliance with applicable regulations.    19. Teligent’s press release quotes Grenfell-Gardner attributing the drop in revenue to  FDA approval delays and competition: ‘“This third quarter has been challenging for Teligent.  These results and our revised outlook for the remainder of the year, are a result of the knock-on  effect of ANDA approval delays and increased competition in one of our largest products[.]’”   20. On the earnings call following the release of the November 2017 8-K, Grenfell- Gardner stated that the Company experienced and addressed undefined manufacturing issues:  New product launches during the quarter certainly helped to mitigate some of the  economic impact of the Lidocaine volume declines. However, new launches do  take time to ramp up.  In addition, our team faced manufacturing challenges, for instance related to an  excipient in a high-volume product that was being provided to us with particles that  had the potential to adulterate our finished goods. The team spent a significant  amount of effort in resolving these challenges, which they now have. However, the  engineering expenses related to the fix contributed to lower-than-anticipated  margins in the quarter. These activities combined with lower lidocaine sales  resulted in margins below our expectations.  23. Plaintiff brings this action as a class action pursuant to Rules 23(a) and (b)(3) of  the Federal Rules of Civil Procedure on behalf of a Class consisting of all those who purchased or  otherwise acquired Teligent securities on U.S. exchanges during the Class Period and were  damaged upon the revelation of the alleged truth (the “Class”).  Excluded from the Class are:  Defendants herein; the officers and directors of the Company, at all relevant times; members of  Defendants’ immediate families and their legal representatives, heirs, successors, or assigns; and  any entity in which Defendants have or had a controlling interest.    24. The members of the Class are so numerous that joinder of all members is  impracticable.  Throughout the Class Period, Teligent common stock was actively traded on the  NASDAQ.  While the exact number of Class members is unknown to Plaintiff at this time, and  can only be ascertained through appropriate discovery, Plaintiff believes that there are thousands  of members in the proposed Class.  The members of the proposed 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 customary forms of notice that are commonly used in securities class  actions.   26. Plaintiff will fairly and adequately protect the interests of the members of the Class  and has retained counsel competent and experienced in class action and securities litigation.   Plaintiff has no interest, antagonism, or conflict with the members of the Class.   27. 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:  a. whether the federal securities laws were violated by Defendants’ acts as  alleged herein;  b. whether statements made by Defendants to the investing public during the  Class Period misrepresented material facts about the business, operations, and management  of Teligent;  c. whether Defendant Grenfell-Gardner caused Teligent to issue false and  misleading financial statements during the Class Period;  d. whether Defendants acted knowingly or recklessly in issuing false and  misleading financial statements;  e. whether the prices of Teligent common stock during the Class Period were  artificially inflated because of Defendants’ conduct complained of herein; and  f. whether the members of the Class have sustained damages and, if so, what  is the proper measure of damages.   29. Plaintiff will rely, in part, upon the presumption of reliance established by the fraud- on-the-market doctrine in that:  a. Defendants made public misrepresentations and/or failed to disclose  material facts during the Class Period;  b. the omissions and misrepresentations were material;  c. Teligent common stock is traded in an efficient market;  d. the Company’s shares were liquid and traded with moderate to heavy  volume during the Class Period;  e. the Company traded on the NASDAQ and was covered by multiple  analysts;  f. the misrepresentations and omissions alleged would tend to induce a  reasonable investor to misjudge the value of the Company’s securities; and  g. Plaintiff and members of the Class purchased, acquired, and/or sold  Teligent common stock between the time Defendants failed to disclose or misrepresented  material facts and the time the true facts were disclosed, without knowledge of the omitted  or misrepresented facts.   30. Based upon the foregoing, Plaintiff and the members of the Class are entitled to a  presumption of reliance upon the integrity of the market.   32. Plaintiff repeats and realleges each and every allegation contained above as if fully  set forth herein.  33. This Count is asserted against all Defendants and based upon violations of §10(b)  of the Exchange Act, 15 U.S.C. §78j(b), and Rule 10b-5 promulgated thereunder by the SEC.   34. During the Class Period, Defendants engaged in a plan, scheme, conspiracy, and  course of conduct, pursuant to which they knowingly or recklessly engaged in acts, transactions,  practices, and courses of business that operated as fraud and deceit upon Plaintiff and the other  members of the Class; made various untrue statements of material facts and 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; and employed devices, schemes, and artifices to defraud  in connection with the purchase and sale of securities.  Such scheme was intended to, and,  throughout the Class Period, did: (i) deceive the investing public, including Plaintiff and the other  members of the Class, as alleged herein; (ii) artificially inflate and maintain the market price of  Teligent common stock; and (iii) cause Plaintiff and the other members of the Class to purchase,  or otherwise acquire, Teligent common stock and options at artificially inflated prices.  In  furtherance of this unlawful scheme, plan, and course of conduct, Defendants took the actions set  forth herein.   36. By virtue of their positions at Teligent, Defendants had actual knowledge of the  materially false and misleading statements and material omissions alleged herein and intended  thereby to deceive Plaintiff and the other members of the Class, or in the alternative, Defendants  acted with reckless disregard for the truth in that they failed or refused to ascertain and disclose  such facts as would reveal the materially false and misleading nature of the statements made,  although such facts were readily available to Defendants.  Said acts and omissions of Defendants  were committed willfully or with reckless disregard for the truth.  In addition, each Defendant  knew or recklessly disregarded that material facts were being misrepresented or omitted, as  described above.   37. Information showing that Defendants acted knowingly or with reckless disregard  for the truth is peculiarly within Defendants’ knowledge and control.  As the senior manager and  director of Teligent, Grenfell-Gardner had knowledge of the details of Teligent’s internal affairs.   39. During the Class Period, Teligent common stock was traded on an active and  efficient market.  Plaintiff and the other members of the Class, relying on the materially false and  misleading statements described herein, which Defendants made, issued, or caused to be  disseminated, or relying upon the integrity of the market, purchased or otherwise acquired shares  of Teligent common stock at prices artificially inflated by Defendants’ wrongful conduct.  Had  Plaintiff and the other members of the Class known the truth, they would not have purchased or  otherwise acquired said securities, or would not have purchased or otherwise acquired them at the  inflated prices that were paid.  At the time of the purchases and/or acquisitions by Plaintiff and the  Class, the true value of Teligent common stock was substantially lower than the prices paid by  Plaintiff and the other members of the Class.  The market price of Teligent common stock declined  sharply upon public disclosure of the facts alleged herein to the injury of Plaintiff and Class  members.    40. By reason of the conduct alleged herein, Defendants knowingly or recklessly,  directly or indirectly, have violated §10(b) of the Exchange Act and Rule 10b-5 promulgated  thereunder.   42. Plaintiff repeats and realleges each and every allegation contained above as if fully  set forth herein.   43. This Count is asserted against Defendant Grenfell-Gardner and based upon  violations of §20(a) of the Exchange Act, 15 U.S.C. §78(t)(a).   44. During the Class Period, Grenfell-Gardner participated in the operation and  management of Teligent and conducted and participated, directly and indirectly, in the conduct of  Teligent’s business affairs.  Because of his senior position as the Company’s President and CEO,  he knew the adverse non-public information alleged herein.   45. As officer and director of a publicly owned company, Grenfell-Gardner had a duty  to disseminate accurate and truthful information, with respect to Teligent’s financial condition and  operations, and promptly correct any public statements issued by Teligent that had become  materially false or misleading.   47. Grenfell-Gardner, therefore, acted as a controlling person of Teligent.  By reason  of his senior management positions and being a director of Teligent, Grenfell-Gardner had the  power to direct the actions of Teligent and exercised same to cause the Company to engage in the  unlawful acts and conduct complained of herein.  Grenfell-Gardner exercised control over the  general operations of Teligent and possessed the power to control the specific activities that  comprise the primary violations about which Plaintiff and the other members of the Class  complain.   48. By reason of the above conduct, Defendant Grenfell-Gardner is liable pursuant to  §20(a) of the Exchange Act for the violations committed by Teligent.  Materially False and Misleading Statements Issued During the Class Period   Violations of §20(a) of the Exchange Act  Against Defendant Grenfell-Gardner   Violations of §10(b) of the Exchange Act and  Rule 10b-5 Promulgated Thereunder  Against All Defendants  