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(1) a significant portion of the Company’s sales of servers were to companies based in China; (2) these transactions violated U.S. export control laws; (3) there were material weaknesses in the Company’s controls to ensure compliance with applicable export control laws and regulations; and (4) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

(1) defendant Soon-Shion materially overstated Anktiva’s capabilities; and (2) as a result, defendants’ statements about ImmunityBio’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(1) defendants emphasized the importance of the enterprise resource planning (ERP) implementation to Vital Farms’ operations and that it was “fundamental to the operational improvements we are planning”; (2) stated the implementation of the ERP would require the time and attention of “management and key crew members”; (3) indeed, defendant Wrede stated that Vital Farms pushed back the expected implementation date of the ERP to “ensure flawless switchover”; (4) given the stated importance of and management’s knowledge of the issues surrounding the implementation of the ERP, defendants knew, or were reckless in not knowing, that implementing the ERP would result in delays of shipments and/or production; (5) defendants did not warn investors that implementing the ERP would result in delays in shipments and/or production, instead merely couching it as a hypothetical in their risk disclosures; and (6) as a result of the delay in shipments and/or production, Vital Farms would lose important retail shelf space, which would negatively impact Vital Farms’ business and operations.

(1) The results of the reproxalap clinical trials were inconsistent; (2) the inconsistency of the results rendered any positive findings from these trials unreliable and not meaningful; and (3) as a result, defendants’ statements about Aldeyra’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(i) Pinterest was experiencing and/or was likely to experience reduced revenues from its advertising partners; (ii) Pinterest overstated its ability to manage the impact of U.S. tariffs on the macroeconomic environment in which the Company operated, including the foreseeable impact on its advertising partners; (iii) the impact of the foregoing on Pinterest’s advertising revenues was significant enough that Pinterest was facing and/or likely to face an imminent restructuring; and (iv) as a result, defendants’ public statements were materially false and misleading at all times.

(1) the Company overstated its progress in its permitting and regulatory filings for its flagship Texas critical data centers project; (2) the Company was involved in a fraudulent scheme “to pocket revenues from hundreds of oil and gas wells in New Mexico” by transferring wells among related entities and then placing liability-bearing companies into bankruptcy to avoid plugging and remediation costs; (3) as a result, the Company’s financial results were false and/or misleading; and (4) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating false and misleading statements and/or concealing material adverse facts concerning the study design for the Company’s Phase 3 PROSERA study, particularly, controlling for the placebo response at the Latin American testing sites. On February 23, 2026, Gossamer published a press release and hosted a Special Call announcing topline results for its Phase 3 PROSERA study, which failed to meet the primary endpoint of improved six-minute walk distance (6MWD) at Week 24, with a +13.3 meter placebo-adjusted gain (p-0.0320) failing to meet the required 0.025 alpha threshold. Gossamer attributed this miss to patients at Latin American sites performing particularly well on placebo due to enrollment of a heavily-treated lower-risk population. Following this news, the price of Gossamer’s common stock declined from a closing market price of $2.13 per share on February 20, 2026 to $0.42 per share on February 23, 2025, a decline of over 80% in the span of just a single day.

(i) the Company's latest iteration of its AI model, Model 22, frequently overreacted to negative macroeconomic signals in performing its risk-separation processes; (ii) accordingly, Model 22’s overall accuracy and propensity to increase loan approval rates was overstated; (iii) Model 22’s overly conservative assessment of credit and macroeconomic conditions was having a significant negative impact on Upstart’s revenue results, rendering the Company’s previously issued FY 2025 revenue guidance unreliable and/or unrealistic; and (iv) as a result, defendants’ public statements were materially false and misleading at all relevant times

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating false and misleading statements and/or concealing material adverse facts concerning the true state of Stellantis’ earnings growth potential, notably, that it was not truly equipped or positioned to grow its adjusted operating income (“AOI”) as forecasted; that electrification was either not truly growing as defendants claimed or that Stellantis was not well positioned to capitalize upon it and convert the opportunity to growth. Instead, Stellantis would ultimately be required to take on considerable charges to adjust its priority, focus, and overall execution in a shift away from battery-powered electric vehicles (“BEV”). On February 6, 2026, Stellantis announced €22 billion in charges alongside a “reset” of the Company’s business and a shortfall, even discounting the charges, against defendants’ previously guided AOI benchmarks. Pertinently, defendants disclosed the charges and reset were due in significant part to the need to shift organizational priorities, stakeholder relationships, supply chains, execution, and quality control due to “an initial overestimation of pace of adoption of electrification in the regions.” Defendants further pointed specifically to “substantially reduced volume and profitability expectations for BEV products.” Following this news, the price of Stellantis’ common stock declined dramatically. From a closing market price of $9.54 per share on February 5, 2026, Stellantis’ stock price fell to $7.28 per share on February 6, 2026, a decline of about 23.69% in the span of just a single day.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating false and misleading statements and/or concealing material adverse facts concerning the true state of Medpace's backlog cancellation rate. Defendants continuously touted "well behaved" cancellation rates. Furthermore, Medpace made clear that cancellations were not caused by weak business or a weak funding environment, providing investors with overly positive growth expectations that could not maintain the projected 1.15 book-to-bill ratio. On February 9, 2026, Medpace issued a press release announcing the Company's fourth quarter 2025 book-to-bill ratio of 1.04, well below the guidance of 1. 15. Following this news, the price of Medpace's common stock declined dramatically. From a closing market price of $530.35 per share on February 9, 2026, Medpace's common stock price fell to $446. 05 per share on February 10, 2026, a decline of more than 15.9%.

(1) the Company’s controlling shareholder, Nieri, intended to force a sale of the Company; (2) Nieri was taking actions to devalue the Company and its financial condition; (3) Nieri leveraged his controlling interest to effectuate that sale, including by effectively forcing the dissident directors to resign; and (4) as a result of the foregoing, Nieri was not acting in the best interests of the Company and public investors.

(i) B&W’s largest shareholder, BRC, stood on both sides of the power generation contract and had close ties to B&W’s counterparty; (ii) Applied Digital did not need the products and services that B&W would purportedly supply pursuant to the power generation LNTP and contract; (iii) the foregoing, at the very least, would raise questions about the parties’ actual intent behind entering into the power generation LNTP and contract, including whether the Company is likely to recognize revenues from these agreements; (iv) accordingly, the business and financial prospects of the Company were overstated; and (v) as a result, defendants’ public statements were materially false and misleading at all relevant times.

According to the filed complaint, during the class period, defendants made materially false and misleading statements and omissions, and engaged in a scheme to deceive the market. This artificially inflated the price of LKQ common stock and operated as a fraud or deceit on the Class. Later, when defendants’ prior misrepresentations and fraudulent conduct were disclosed to the market, the price of LKQ common stock declined significantly as the prior artificial inflation came out over time. As a result of their purchases of LKQ common stock during the class period, members of the class suffered economic loss.

According to the filed complaint, defendants made false and/or misleading statements and/or failed to disclose that Globant’s Latin American operations began experiencing turmoil in late 2023. Latin America was not, as defendants claimed, a “particularly beneficial” region that would allow for the “ability to grow” Globant’s business. Nor was the market in Latin America “stable” or “improving a lot.” In truth, Globant was facing decreasing demand across Latin America and had frozen wages in both Argentina and Mexico in late 2023 and Latin American clients were reducing and cancelling their projects with the Company. Moreover, it was misleading for Globant to discuss the effects of the depreciation of the Argentine currency on its project contracts without disclosing that it had frozen the wages of its Argentine employees and that, because of currency depreciation, those wage freezes amounted in practical terms to wage cuts.

(i) Regencell was vulnerable and/or subject to market manipulation; (ii) the resulting volatility in the market for the Company’s ordinary shares exposed Regencell’s investors to significant financial risk; (iii) all the foregoing subjected Regencell to a heightened risk of regulatory and/or governmental scrutiny and enforcement action, as well as significant legal, monetary, and reputational harm; and (iv) as a result, defendants’ public statements were materially false and misleading at all relevant times.

(1) SES AI overstated its business prospects by materially overstating the expected results that could be achieved by deals with companies that have limited or no operations; (2) SES AI created an appearance of revenue by purchasing services in exchange for purchases of molecular universe; (3) Contrary to its positive statements regarding growth prospects, SES AI was affected by material logistics constraints in the fourth quarter of 2025 which would materially affect Q4 2025 revenues; (4) the foregoing called into question SES AI’s growth prospects for 2026, which were confirmed due to lower than expected 2026 revenue guidance; and (5) as a result, defendants’ statements about SES AI’s business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(1) POET Technologies misrepresented its tax status due to it likely being deemed a passive foreign investment company under U.S. tax laws which, if not properly reported by each U.S. stockholder, would have negative tax implications for those U.S. stockholders; (2) the foregoing tax issue would, if discovered, make POET Technologies a less attractive investment than it would otherwise be, thus threatening POET Technologies’ valuation; (3) defendant, despite affirming that he was not violating a non-disclosure agreement, in fact violated a business agreement by speaking about POET Technologies’ business agreements in a public interview, thus endangering POET Technologies’ business prospects, and (4) as a result, defendants’ statements about POET Technologies’ business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(1) the Company overstated the effectiveness of its portfolio restructuring efforts for its nonaccrual companies; (2) the Company overstated the valuation of its portfolio investments and/or overstated the effectiveness of the Company’s portfolio valuation process; (3) the Company overstated the durability of its quarterly distribution strategy; and (4) that, as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

(i) Graphic Packaging was experiencing, inter alia, significant inventory management issues, as well as significantly reduced demand and volumes and increased costs; (ii) defendants downplayed the true scope and severity of the foregoing issues, which were likely to, and did, have a material negative impact on the Company’s business and financial results; (iii) defendants likewise overstated the strength and sustainability of the Company’s business model and operations, as well as its ability to weather ongoing macroeconomic headwinds; (iv) accordingly, the Company’s previously issued FY 2025 financial guidance was unreliable and/or unrealistic; and (v) as a result, defendants’ public statements were materially false and misleading at all relevant times.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating false and misleading statements and/or concealing material adverse facts concerning the efficacy and safety of its TACTI-004 Phase III clinical trial study. On March 13, 2026, Immutep issued a press release announcing that the Independent Data Monitoring (IDMC) for the TACTI-004 Phase III study recommended that the trial be discontinued following a planned interim futility analysis. Further, based on its review of the available safety and efficacy data, the IDMC recommended that the trial be discontinued for futility. Following this news, the price of Immutep’s ADRs declined dramatically. From a closing market price of $2.76 per share on March 12, 2026, Immutep’s stock price fell to $0.48 per share on March 13, 2026, a decline of about 83%.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of Phreesia’s slowing demand and reduced visibility in key revenue streams, notably, the weakened pharmaceutical marketing commitments in its Network Solutions segment. On March 30, 2026, Phreesia announced significantly reduced revenue growth projections for fiscal year 2027 guidance. The Company attributed the shortfall against its prior guidance to a combination of macroeconomic factors including “worsening visibility” and weaker pharmaceutical marketing commitments within its Network Solutions segment. Following this news, the price of Phreesia’s common stock declined from a closing market price of $11.41 per share on March 30, 2025, to $8.38 per share on March 31, 2026, a decline of about 27%.

(1) Sportradar intentionally worked with black-market gambling operators to increase its revenues, despite its assurances of strict legal and regulatory compliance and claims that ethics and integrity were crucial for Sportradar’s operations; (2) the Company’s know-your-customer and compliance processes were not as robust as defendants’ had claimed; and (3) as a result, defendants’ statements about the Company’s business, operations, and prospects lacked a reasonable basis.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of Commvault’s ARR growth environment; pertinently, Commvault knew or recklessly disregarded that the Company’s ARR growth guidance failed to properly factor in crucial variables, such as the type of sale. On January 27, 2026, Commvault published third quarter 2026 fiscal results, which included ARR growth below the guidance provided by the Company. In particular, ARR growth for the third quarter 2026 was $39 million, which fell short of the $45 million projection provided. Following this news, the price of Commvault’s common stock declined dramatically. From a closing market price of $129.36 per share on January 26, 2026, Commvault’s stock price fell to $89.13 per share on January 27, 2026, a decline of over 31% in a single day.