This action arises out of Lehman Brothers Holdings Inc.'s ("Lehman" or the "Company") issuance of hundreds of offerings of debt and equity securities, for collective proceeds of more than $47 billion, pursuant to offering materials that contained untrue statements and omitted material information. For example, Lehman’s offering materials contained untrue statements and omitted material information regarding Lehman’s: (1) significant and increasing concentration of mortgage related risks; (2) failure to record write downs of its mortgage and real estate related investments in a timely or adequate fashion; (3) high risk residential mortgage lending practices; (4) risk mitigation and inability to hedge against losses in its mortgage related portfolio; and (5) capitalization, liquidity, and risks of bankruptcy. Ultimately, Lehman petitioned for bankruptcy on September 15, 2008 – the largest bankruptcy in the history of the United States.

Lehman, once one of the nation's most prominent financial institutions, was a major participant in all aspects of the mortgage and real estate markets, including originating residential and commercial mortgages, securitizing loans, marketing asset-backed instruments, and investing directly in real estate. As revelations of delinquencies and defaults in the U.S. mortgage markets mounted and the credit markets declined, and as other institutions booked massive mortgage and real estate related losses, however, Lehman failed to write down its assets in a timely and adequate manner, and its disclosures did not reveal its exposure to mortgage and real estate related losses.

Ultimately, the truth about Lehman's financial condition and illiquid assets materialized in a series of announcements and events, concluding with Lehman’s bankruptcy filing on September 15, 2008.