According to the Complaint, Semiconductor Manufacturing International Corporation ("SMIC" or the "Company") purports to be an investment holding company principally engaged in the computer-aided design, manufacture, testing, packaging and trading of integrated circuits ("IC"), as well as the provision of other semiconductor services. The Company is also involved in the design and manufacture of semiconductor masks and various types of wafers. The Company distributes its products in China and to overseas markets, such as the Europe and the United States.

The Complaint alleges Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) there was an "unacceptable risk" that equipment supplied to SMIC would be used for military purposes; (2) SMIC was foreseeably at risk of facing U.S. restrictions; (3) as a result of restrictions by the U.S. Department of Commerce, certain of SMIC's suppliers would need "difficult-to-obtain" individual export licenses; and (4) as a result, Defendants' public statements were materially false and/or misleading at all relevant times.