Lawsuit against BERKSHIRE HATHAWAY ENERGY COMPANY

```html Lawsuit Against Berkshire Hathaway Energy

Class Action Complaint

United States District Court for the Southern District of New York

Plaintiffs

[Plaintiff Names], Individually and On Behalf of All Others Similarly Situated, Plaintiffs,

Defendants

Berkshire Hathaway Energy Company, including its subsidiaries such as PacifiCorp, MidAmerican Funding, NV Energy, and other relevant entities.

Introduction

This class action complaint is brought by [Plaintiff Names], individually and on behalf of all others similarly situated, against Berkshire Hathaway Energy Company and its subsidiaries for violations of federal securities laws and state consumer protection laws.

Jurisdiction and Venue

This Court has jurisdiction over the subject matter of this action pursuant to Section 27 of the Securities Exchange Act of 1934 and 28 U.S.C. § 1331. Venue is proper in this District under Section 27 of the Exchange Act and 28 U.S.C. § 1391(b).

Parties

Plaintiffs [Names] are investors who purchased Berkshire Hathaway Energy securities during the Class Period and have suffered damages due to Defendants’ wrongful conduct. Defendant Berkshire Hathaway Energy Company is an Iowa corporation with its principal executive offices located in Des Moines, Iowa.

Facts

  • During the Class Period, Defendants made materially false and misleading statements regarding the Company’s financial performance, regulatory compliance, and cybersecurity measures.
  • Defendants misrepresented the impact of rate regulation on financial statements, resulting in misleading information to investors and consumers.
  • Defendants failed to properly disclose and account for goodwill impairment, leading to inflated asset values and financial instability.
  • Defendants did not adequately disclose cybersecurity risks and incidents, impacting investor decisions and consumer trust.
  • Defendants failed to comply with environmental regulations and disclose ongoing legal and regulatory proceedings, further misleading investors.
  • Defendants mismanaged credit exposure, leading to undisclosed financial risks and potential instability.

Causes of Action

Count I: Violation of Section 10(b) of the Exchange Act and Rule 10b-5 Against All Defendants

Plaintiffs repeat and reallege each and every allegation contained above as if fully set forth herein. Defendants carried out a plan, scheme, and course of conduct which was intended to and did deceive the investing public regarding the financial condition and prospects of Berkshire Hathaway Energy.

Count II: Violation of Section 20(a) of the Exchange Act Against Individual Defendants

Plaintiffs repeat and reallege each and every allegation contained above as if fully set forth herein. The Individual Defendants acted as controlling persons of Berkshire Hathaway Energy within the meaning of Section 20(a) of the Exchange Act.

Count III: Violation of State Consumer Protection Laws

Plaintiffs repeat and reallege each and every allegation contained above as if fully set forth herein. Defendants engaged in unfair and deceptive trade practices in violation of [specific state laws], causing harm to consumers.

Prayer for Relief

WHEREFORE, Plaintiffs pray for relief and judgment, as follows:

  • Awarding compensatory damages in favor of Plaintiffs and the other Class members against all Defendants for all damages sustained as a result of Defendants’ wrongdoing, in an amount to be proven at trial, including interest thereon;
  • Awarding Plaintiffs and the Class their reasonable costs and expenses incurred in this action, including counsel fees and expert fees;
  • Granting injunctive relief to prevent further violations of securities laws and to improve transparency and compliance measures within Berkshire Hathaway Energy;
  • Ordering restitution and refunds to consumers for overcharges resulting from improper rate regulation practices;
  • Such other and further relief as the Court may deem just and proper.

Jury Trial Demanded

Plaintiffs hereby demand a trial by jury.

Respectfully submitted,

[Attorney's Name]

[Law Firm Name]

[Address]

[City, State, Zip]

[Telephone]

[Email]

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