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It is alleged in this complaint that (i) Philips’ product manufacturing controls or procedures were deficient; (ii) Philips’ mechanical ventilators and Bi-Level PAP and CPAP devices were manufactured using hazardous materials, as a result; (iii) accordingly, Philips’ sales revenues in relation to the foregoing products were unsustainable; (iv) the foregoing also subjected Philips to a substantial risk of a product recall, as well as potential legal and/or regulatory action; and (v) Philips’ public statements were materially false and misleading at all relevant times, as a result.