Concho Resources, Inc.
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It is alleged in this complaint that Concho made misleading and/or false statements and/or failed to disclose that: (1) the well spacing at Dominator Project was highly risky and aggressive, and premised on no reasonable basis to believe it would work as intended; (2) Concho’s practice of implementing tighter well spacing was not limited to a handful of “tests”, therefore more widespread than the market was led to believe; (3) it was known or recklessly disregarded that measures to mitigate well spacing risks were non-existent and/or impossible; (4) these risks were evident during the Class Period, which caused underground well interference and permanently decreasing production, forcing Concho to scale back production targets, adopting more conservative spacing measures in its other projects; (5) it would take multiple quarters to reverse the impacts of this widespread well spacing failure; and (6) Concho’s public statements were misleading and materially false at all relevant times, as a result.