According to the Complaint, Restaurant Brands International Inc. is one of the world's largest restaurant chains with over 27,000 Tim Hortons, Burger King, and Popeyes restaurants in more than 100 countries and U.S. territories as of December 31, 2019.

The Complaint alleges that, throughout the Class Period, the Defendants repeatedly touted the implementation and execution of Restaurant Brands' Winning Together Plan and Tims Rewards loyalty program. On the heels of Restaurant Brands touting the benefits of these initiatives, the company completed two stock offerings on or about August 12, 2019, and September 5, 2019, collectively resulting in proceeds of approximately $3 billion to insiders. The Complaint further alleges that, throughout the Class Period, the Defendants misrepresented and/or failed to disclose that: (1) Restaurant Brands' Winning Together Plan was failing to generate substantial, sustainable improvement within the Tim Hortons brand; (2) the Tims Rewards loyalty program was not generating sustainable revenue growth as increased customer traffic was not offsetting promotional discounting; and (3) as a result, the Defendants' statements about Restaurant Brands' business, operations, and prospects lacked a reasonable basis.