| Levi & Korsinsky, LLP | Securities Class Action Attorneys

55

Days Left

ECG

Everus Construction Group, Inc.

Deadline

June 3 2025

Class Period

10/31/24 - 2/11/25

Allegations

(1) the Company’s backlog conversion cycle had become elongated due to larger, more complex projects; (2) as a result, the Company’s revenue recognition would be delayed; and (3) 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.

Class Period

10/31/24 - 2/11/25

Deadline

June 3 2025

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55

Days Left

VTRS

Viatris Inc.

Deadline

June 3 2025

Class Period

8/8/24 - 2/26/25

Allegations

According to the complaint, defendants provided investors with material information concerning the failed inspection of Viatris’ Indore, India facility. Defendants’ statements misrepresented the FDA’s issuance of a warning letter and its impact on Viatris' operations. Defendants routinely referred to the impact of the warning letter as a mere “minor headwind” for the Company. On February 27, 2025, Viatris announced its financial results for the fourth quarter and full fiscal year 2024 and provided disappointing fiscal 2025 guidance. The Company attributed below-expectation guidance on “the expected financial impact from Indore facility warning letter and import alert.” Following this news, the price of Viatris’ common stock declined dramatically. From a closing market price of $11.24 per share on February 26, 2025, Viatris’ stock price fell to $9.53 per share on February 27, 2025, a decline of about 15.21% in the span of just a single day.

Class Period

8/8/24 - 2/26/25

Deadline

June 3 2025

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55

Days Left

ABBV

Cerevel Therapeutics Holdings, Inc.

Deadline

June 3 2025

Class Period

This lawsuit is on behalf of all persons or entities that: (a) sold or otherwise disposed of the publicly-traded common stock of Cerevel during the period from October 11, 2023 through August 1, 2024, inclusive. (b) held shares of Cerevel as of the January 8, 2024 record date and were entitled to vote on the merger of Cerevel and AbbVie Inc. (c) sold shares of Cerevel stock contemporaneously with Bain Capital’s purchase of shares on or about October 16, 2023.

Allegations

According to the complaint, Cerevel’s October 16, 2023 secondary stock offering (the “October Offering” or “Offering”) documents and other public statements omitted material facts regarding AbbVie’s interest in acquiring Cerevel at a price well in excess of the $22.81 per share Offering price, artificially deflating Cerevel’s stock price until the merger was announced. Moreover, Cerevel’s controlling shareholder, Bain Capital Investors, LLC (“Bain”), acquired Cerevel shares from the October Offering at an artificially depressed price while allegedly in possession of material nonpublic information regarding AbbVie’s interest. On December 6, 2023, Cerevel publicly announced that AbbVie agreed to acquire Cerevel for $45 per share. The merger allowed Bain to receive a windfall of more than $120 million on the shares it acquired at the artificially depressed Offering price. In addition, Cerevel’s January 18, 2024 Proxy statement misled investors regarding the true nature and timing of AbbVie’s interest in Cerevel.

Class Period

This lawsuit is on behalf of all persons or entities that: (a) sold or otherwise disposed of the publicly-traded common stock of Cerevel during the period from October 11, 2023 through August 1, 2024, inclusive. (b) held shares of Cerevel as of the January 8, 2024 record date and were entitled to vote on the merger of Cerevel and AbbVie Inc. (c) sold shares of Cerevel stock contemporaneously with Bain Capital’s purchase of shares on or about October 16, 2023.

Deadline

June 3 2025

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2

Days Left

ICLR

ICON Public Limited Company

Deadline

April 11 2025

Class Period

7/27/23 - 1/13/25

Allegations

(a)ICON was suffering from a material loss of business due to customer cost reduction measures and other widespread funding limitations impacting the Company’s client base; (b)ICON’s purported functional service provision and hybrid model offerings were insufficient to shield the Company from the adverse effects of a significant market downturn; (c) the requests for proposals ICON received from its biotechnology customers during the Class Period were used in substantial part as price discovery tools, and thus were not indicative of underlying client demand; (d)ICON’s customers had canceled contracts, limited or reduced engagements, delayed clinical trial work, and/or failed to enter into new contracts with ICON for additional clinical trial work at historical rates once existing projects ended (or were scheduled to end) in 2024; (e)ICON’s two largest customers were diversifying their clinical research organization providers away from the Company; (f)as a result of (a)-(e) above, ICON’s reported net new business awards and book-to-bill metrics materially misrepresented client demand for ICON’s services; and (g)as a result of (a)-(f) above, ICON was tracking materially below the 2024 revenue and EPS guidance issued during the Class Period and such guidance lacked a reasonable factual basis.

Class Period

7/27/23 - 1/13/25

Deadline

April 11 2025

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5

Days Left

ESTC

Elastic N.V.

Deadline

April 14 2025

Class Period

5/31/24 - 8/29/24

Allegations

(i) Elastic had implemented significant changes to its sales operations, particularly with respect to its customer segments in the Americas; (ii) the foregoing changes were likely to, and did, disrupt Elastic’s sales operations during the first quarter of its FY 2025; (iii) accordingly, defendants had overstated the stability of Elastic’s sales operations; (iv) as a result of all the foregoing, Elastic was unlikely to meet its own previously issued revenue guidance for its FY 2025; and (v) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

5/31/24 - 8/29/24

Deadline

April 14 2025

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5

Days Left

NTLA

Intellia Therapeutics, Inc.

Deadline

April 14 2025

Class Period

7/30/24 - 1/8/25

Allegations

According to the complaint, defendants provided investors with material information concerning Intellia's Phase 1/2 study evaluating NTLA-3001 for the treatment of alpha-1 antitrypsin deficiency (AATD)-associated lung disease. Defendants’ statements included, among other things, confidence in the Company’s timeline for the aforementioned study, specifically that Intellia expected to dose the first patient in the second half of 2024. Defendants failed to disclose inter alia that the demand for viral-based editing was rapidly dwindling as non-viral delivery methods became a main target of the scientific research community due to their cost-effectiveness and more efficient development, thus making NTLA-3001 an inefficient program for Intellia to maintain. The truth emerged on January 9, 2025, when Intellia published a press release announcing Company reorganization. In pertinent part, defendants disclosed that Intellia would be halting all NTLA-3001 research and studies and that the Company would be reducing its workforce by 27% in 2025. Specifically, the Company announced that management decided to focus Intellia’s resources on other pharmaceutical development and would be implementing cost saving in the form of a major reduction in force. As a result, defendants pipeline priority readjustment resulted in the Company’s once-touted NTLA-3001’s discontinuation. Following this news, Intellia’s stock price fell from a closing market price of $12.02 per share on January 8, 2025 to $10.20 per share on January 10, 2025.

Class Period

7/30/24 - 1/8/25

Deadline

April 14 2025

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5

Days Left

EIX

Edison International

Deadline

April 14 2025

Class Period

2/25/21 - 2/6/25

Allegations

(1) Edison’s claim that southern California Edison company used its public safety power shutoffs program to “proactively de-energize power lines to mitigate the risk of catastrophic wildfires during extreme weather events”, was false; (2) this resulted in heightened fire risk in California and heightened legal exposure to the Company; and (3) as a result, defendants’ statements about Edison’s business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all times.

Class Period

2/25/21 - 2/6/25

Deadline

April 14 2025

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5

Days Left

MRK

Merck & Co., Inc.

Deadline

April 14 2025

Class Period

2/3/22 - 2/3/25

Allegations

According to the complaint, defendants provided investors with material information concerning Merck’s expected revenue of $11 billion from sales of Gardasil by 2030. Defendants’ statements included, among other things, confidence in Merck’s purported ability to utilize successful consumer activation and education efforts on the benefits of Gardasil in order to drive demand and capitalize on eligible populations for vaccination, resulting in confidently optimistic reports and forecasts of Gardasil’s growth in China. The full truth finally emerged on February 4, 2025, when Merck announced it would no longer achieve the long-forecasted $11 billion in sales of Gardasil by 2030, as it would cease shipments of Gardasil to China “through at least midyear” to facilitate a “rapid reduction of inventory.” Defendants claimed this was necessitated by the continued over-inflation of overall channel inventories as demand in China for Gardasil had “not recovered to the level we had expected.” Following this news, Merck’s common stock declined dramatically. From a closing market price of $99.79 per share on February 3, 2025, Merck’s stock price fell to $90.74 per share on February 4, 2025, a decline of more than 9% in the span of just a single day.

Class Period

2/3/22 - 2/3/25

Deadline

April 14 2025

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5

Days Left

FMC

FMC Corporation

Deadline

April 14 2025

Class Period

11/16/23 - 2/4/25

Allegations

(1) the Company’s channel management initiatives were not progressing as represented; (2) faced with pricing pressure, the Company had made the decision not to compete on prices and instead walk away from sales opportunities; (3) the Company had inflated inventory in the channels in “Latin America, including Brazil, Asia, including India, as well as Canada and Eastern Europe;” 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.

Class Period

11/16/23 - 2/4/25

Deadline

April 14 2025

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6

Days Left

TMDX

TransMedics Group, Inc.

Deadline

April 15 2025

Class Period

2/28/23 - 1/10/25

Allegations

(1) TransMedics used kickbacks, fraudulent overbilling, and coercive tactics to generate business and revenue; (2) TransMedics engaged in unsafe practices and hid safety issues and generally lacked safety oversight; (3) the foregoing subjected TransMedics to heightened risk of scrutiny and regulatory risk; and (4) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

Class Period

2/28/23 - 1/10/25

Deadline

April 15 2025

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6

Days Left

ALAR

Alarum Technologies Ltd.

Deadline

April 15 2025

Class Period

3/14/24 - 8/26/24

Allegations

(i) the Company was less effective in retaining and/or expanding customer engagements than it had represented to investors; (ii) the foregoing would impair Alarum’s ability to generate consistent revenue growth; (iii) accordingly, Alarum’s business and/or financial prospects were overstated; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

3/14/24 - 8/26/24

Deadline

April 15 2025

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9

Days Left

VG

Venture Global, Inc.

Deadline

April 18 2025

Class Period

This lawsuit is on behalf of all shareholders that purchased stock pursuant and/or traceable to Venture’s registration statement for the initial public offering held on or about January 24, 2025.

Allegations

According to the complaint, Venture completed its initial public offering on January 27, 2025, selling 70 million shares at $24.00 per share. On February 5, 2025, TotalEnergies, an energy company that was a target customer of Venture, rejected opportunities to become a long-term customer of Venture, citing lack of trust. In particular, TotalEnergies CEO, stated that he was approached by Venture to see if the company would be interested in a long-term supply contract for liquefied natural gas from the Calcasieu Pass terminal in Louisiana, but he rejected the offer “because of what they are doing.” Venture is currently facing legal challenges from existing large clients, such as BP and Shell, due to delays in supply contracts as Venture commissions its projects. Given the fact that defendants ability to deliver liquefied natural gas (LNG) to the world and to continue development of Venture’s five natural gas liquefication and export projects depends on customer contracts, defendants’ failure to account for and address these issues caused statements in Venture’s registration statement to be false and/or materially misleading at the time of the initial public offering.

Class Period

This lawsuit is on behalf of all shareholders that purchased stock pursuant and/or traceable to Venture’s registration statement for the initial public offering held on or about January 24, 2025.

Deadline

April 18 2025

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12

Days Left

STZ

Constellation Brands, Inc.

Deadline

April 21 2025

Class Period

4/11/24 - 1/8/25

Allegations

According to the complaint, defendants provided investors with material information concerning Constellation’s full year 2024 fiscal results and financial outlook for 2025 which was based in material part on defendants enhanced focus on improving mix, inventory and sales execution in its Wine and Spirits business, specifically focusing efforts within its premium and above brands to drive more consistent growth. Additionally, defendants made investments in media spend and price promotions as well as adjustments in sales capabilities to support distributor partners. On January 8, 2025 defendants issued a press release announcing the Company’s third quarter fiscal year 2025 results. In pertinent part, defendants presented a significant miss on sales performance in the Beer segment and an even steeper miss for the Wine & Spirits. Following this news, the price of Constellation’s common stock declined dramatically. From a closing market price of $219.28 per share on January 8, 2025 to $181.81 per share on January 10, 2025.

Class Period

4/11/24 - 1/8/25

Deadline

April 21 2025

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12

Days Left

TTD

The Trade Desk, Inc.

Deadline

April 21 2025

Class Period

5/9/24 - 2/12/25

Allegations

(1) Trade Desk was experiencing significant, ongoing, self-inflicted execution challenges rolling out the Company's AI forecasting tool, Kokai, including transitioning clients to Kokai from the Company’s older platform Solimar; (2) such execution challenges meaningfully delayed the Kokai Rollout; (3) Trade Desk’s inability to effectively execute the Kokai Rollout negatively impacted the Company’s business and operations, particularly revenue growth; and (4) as a result of the above, Defendants’ positive statements about the Company’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

Class Period

5/9/24 - 2/12/25

Deadline

April 21 2025

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13

Days Left

SMTC

Semtech Corporation

Deadline

April 22 2025

Class Period

8/27/24 - 2/7/25

Allegations

(1) its CopperEdge products did not meet the needs of its server rack customer or end users; (2) as a result, the CopperEdge products required certain rack architecture changes; (3) as a result of the foregoing, the Company’s sales of CopperEdge products would not ramp-up during fiscal 2026; (4) as a result, sales of CopperEdge products would be lower-than-expected; and (5) 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.

Class Period

8/27/24 - 2/7/25

Deadline

April 22 2025

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14

Days Left

ATKR

Atkore Inc.

Deadline

April 23 2025

Class Period

2/1/24 - 2/3/25

Allegations

(1) Atkore engaged in an anticompetitive price-fixing scheme that artificially inflated the price of PVC Pipes; (2) Atkore reaped significant, unsustainable financial benefits from its anticompetitive conduct; (3) as Atkore’s price-fixing scheme was exposed, the Company and its price-fixing co-conspirators were no longer able to artificially inflate the price of PVC Pipes, resulting in a substantial decrease in the price of PVC Pipes; (4) Atkore’s business and operations were negatively impacted; and (5) as a result, defendants’ positive statements Company’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

Class Period

2/1/24 - 2/3/25

Deadline

April 23 2025

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19

Days Left

QUBT

Quantum Computing Inc.

Deadline

April 28 2025

Class Period

3/30/20 - 1/15/25

Allegations

(i) defendants overstated the capabilities of QCI’s quantum computing technologies, products, and/or services; (ii) defendants overstated the scope and nature of QCI’s relationship with NASA, as well as the scope and nature of QCI’s NASA-related contracts and/or subcontracts; (iii) defendants overstated QCI’s progress in developing a thin film lithium niobate, TFLN foundry, the scale of the purported TFLN foundry, and orders for the Company’s TFLN chips; (iv) QCI’s business dealings with Quad M and millionways both qualified as related party transactions; (v) accordingly, QCI’s revenues relied, at least in part, on undisclosed related party transactions; (vi) all the foregoing, once revealed, was likely to have a significant negative impact on QCI’s business and reputation; and (vii) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

3/30/20 - 1/15/25

Deadline

April 28 2025

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19

Days Left

MANH

Manhattan Associates, Inc.

Deadline

April 28 2025

Class Period

10/22/24 - 1/28/25

Allegations

According to the complaint, defendants provided investors with material information concerning Manhattan Associates’ expected revenue for the fiscal year 2025. Defendants’ statements included, among other things, confidence in the Company’s ability to forecast guidance despite macroeconomic fluctuations, the growth potential of their professional services offerings, and the ability for their cloud revenue to drive revenue for its professional services. On January 28, 2025, Manhattan Associates published its financial results for the fourth quarter and full fiscal year 2024 and announced reduced revenue guidance for the full fiscal year 2025. The Company attributed its results and lowered guidance on the “shift in professional services work to future periods . . . and to a lesser extent, reduced customization and higher partner utilization.” Following this news, the price of Manhattan Associates’ common stock declined dramatically from a closing market price of $295.10 per share on January 28, 2025, to $222.84 per share on January 29, 2025, a decline of about 24.49% in the span of just a single day.

Class Period

10/22/24 - 1/28/25

Deadline

April 28 2025

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19

Days Left

RKLB

Rocket Lab USA, Inc.

Deadline

April 28 2025

Class Period

11/12/24 - 2/25/25

Allegations

(1) the Company’s plans for three barge landing tests were significantly delayed; (2) a critical potable water problem was not scheduled to be fixed until January 2026, which delayed preparation of the launch pad; (3) as a result of the foregoing, there was a substantial risk that Rocket Lab’s Neutron rocket would not launch in mid-2025; (4) Neutron’s only contract was made at a discount with an unreliable partner; and (5) 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.

Class Period

11/12/24 - 2/25/25

Deadline

April 28 2025

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26

Days Left

ELF

e.l.f. Beauty, Inc.

Deadline

May 5 2025

Class Period

11/1/23 - 11/19/24

Allegations

(i) contrary to its representations to investors, the Company was experiencing rising inventory levels as a consequence of flagging sales; (ii) Elf falsely attributed the rising inventory levels to, among other things, changes in its sourcing practices; (iii) to maintain investor confidence, Elf reported inflated revenue, profits, and inventory over several quarters; (iv) the Company’s business and/or financial prospects were overstated; (v) all of the foregoing, once revealed, would likely have a material negative impact on the Company; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

11/1/23 - 11/19/24

Deadline

May 5 2025

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26

Days Left

SWKS

Skyworks Solutions, Inc.

Deadline

May 5 2025

Class Period

7/30/24 - 2/5/25

Allegations

According to the complaint, defendants provided investors with material information concerning Skyworks’ expected revenue for the fiscal year 2025. Defendants’ statements included, among other things, confidence in Skyworks’ ability to expand its mobile business and capitalize on its growth potential by investing in new technologies to diversify its portfolio of offerings. On February 5, 2025, after market close, Skyworks announced its financial results for the first quarter of fiscal year 2025 and provided lower-than anticipated revenue guidance for the second quarter of fiscal year 2025. The Company attributed its results and low guidance to a “competitive landscape” that had “intensified” in recent years. Following this news, the price of Skyworks’ common stock declined dramatically. From a closing market price of $87.08 per share on February 5, 2025, Skyworks’ stock price fell to $65.60 per share on February 6, 2025, a decline of over 24% in the span of just a single day.

Class Period

7/30/24 - 2/5/25

Deadline

May 5 2025

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26

Days Left

APP

AppLovin Corporation

Deadline

May 5 2025

Class Period

5/10/23 - 2/25/25

Allegations

According to the complaint, defendants provided investors with material information concerning AppLovin’s financial growth and stability. Defendants’ statements included, among other things, confidence in AppLovin’s launch of its AXON 2.0 digital ad platform and using “cutting-edge AI technologies” to more efficiently match advertisements to mobile games, in addition to expanding into web-based marketing and e-commerce. Moreover, defendants publicly reported impressive financial results, outlooks, and guidance to investors, all while using dishonest advertising practices. The truth emerged on February 26, 2025, when analyst research reports emerged stating that AppLovin was reverse engineering and exploiting advertising data from Meta Platforms. The reports further alleged AppLovin was utilizing manipulative practices to artificially inflate their own ad click-through and app download rates, such as by having ads click on themselves or utilizing design gimmicks to trigger forced shadow downloads, erroneously inflating installation numbers and, in turn, its profit figures. Following this news, the price of AppLovin’s stock declined from $377.06 per share on February 25, 2025 to $331.00 per share on February 26, 2025.

Class Period

5/10/23 - 2/25/25

Deadline

May 5 2025

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26

Days Left

MRVI

Maravai LifeSciences Holdings, Inc.

Deadline

May 5 2025

Class Period

8/7/24 - 2/24/25

Allegations

(1) Maravai lacked adequate internal controls over financial reporting related to revenue recognition; (2) as a result, the Company inaccurately recognized revenue on certain transactions during fiscal 2024; (3) its goodwill was overstated; 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.

Class Period

8/7/24 - 2/24/25

Deadline

May 5 2025

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26

Days Left

RC

Ready Capital Corporation

Deadline

May 5 2025

Class Period

11/7/24 - 3/2/25

Allegations

(1) significant non-performing loans in its CRE portfolio were not likely to be collectible; (2) Ready Capital would fully reserve these problem loans in order to “stabilize” its CRE portfolio; (3) this was not accurately reflected in Ready Capital’s current expected credit loss or valuation allowances; (4) as a result, the Company’s financial results would be adversely affected; and (5), 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.

Class Period

11/7/24 - 3/2/25

Deadline

May 5 2025

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30

Days Left

NEP

XPLR Infrastructure, LP

Deadline

May 9 2025

Class Period

1/26/21 - 1/27/25

Allegations

(i) XPLR was struggling to maintain its operations as a yieldco; (ii) defendants temporarily relieved this issue by entering into CEPF, convertible equity portfolio financing arrangements while downplaying the attendant risks; (iii) XPLR could not buy out CEPFs before their maturity date without risking significant unitholder dilution; (iv) as a result, defendants planned to halt cash distributions to investors and instead redirect those funds to, inter alia, buy out the Company’s CEPFs; (v) as a result of all the foregoing, XPLR’s yieldco business model and distribution growth rate was unsustainable; and (vi) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

1/26/21 - 1/27/25

Deadline

May 9 2025

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33

Days Left

FLNC

Fluence Energy, Inc.

Deadline

May 12 2025

Class Period

11/29/23 - 2/10/25

Allegations

(1) Fluence’s relationship with its founders and largest sources of revenue, Siemens AG and The AES Corporation, was poised to decline; (2) Siemens Energy, Siemens AG’s U.S. affiliate, had accused the Company of engineering failures and fraud; (3) Fluence’s margins and revenue growth were inflated as Siemens and AES were moving to divest; and (4) based on the foregoing, defendants lacked a reasonable basis for their positive statements related to Fluence’s battery energy storage business, as well as related financial results, growth, and prospects.

Class Period

11/29/23 - 2/10/25

Deadline

May 12 2025

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33

Days Left

GERN

Geron Corporation

Deadline

May 12 2025

Class Period

6/7/24 - 2/25/25

Allegations

According to the complaint, defendants provided investors with material information concerning defendants’ expectations for the launch and growth potential of Rytelo (imetelstat). Defendants’ statements included, among other things, confidence in Geron’s ability to capitalize on the purportedly significant unmet need for the drug and to execute on its commercial plan to target first-line ESA ineligible patients, while continually minimizing the risks associated with the burden of the weekly monitoring requirement for Rytelo and the impacts of seasonality and existing competition on the drug’s sales. On February 26, 2025, Geron announced its financial results for the fourth quarter of fiscal 2024, disclosing that Rytelo’s growth had flattened over the preceding months. The Company attributed the diminished growth on seasonality, competition, lack of awareness for Rytelo, and the burden of the monitoring requirement necessary for the drug treatment. Following this news, the price of Geron’s common stock declined dramatically. From a closing market price of $2.37 per share on February 25, 2025, Geron’s stock price fell to $1.61 per share on February 26, 2025, a decline of about 32.07% in the span of just a single day.

Class Period

6/7/24 - 2/25/25

Deadline

May 12 2025

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34

Days Left

TFII

TFI International Inc.

Deadline

May 13 2025

Class Period

4/26/24 - 2/19/25

Allegations

(1) the Company was losing small and medium business customers; (2) as a result, the Company’s TForce revenue was declining; (3) TFI was experiencing difficulties managing its costs; (4) as a result of the foregoing, the profitability of its largest business segment was declining; and (5) 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.

Class Period

4/26/24 - 2/19/25

Deadline

May 13 2025

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34

Days Left

EU

enCore Energy Corp.

Deadline

May 13 2025

Class Period

3/28/24 - 3/2/25

Allegations

(1) enCore lacked effective internal controls over financial reporting; (2) enCore could not capitalize certain exploratory and development costs under GAAP; (3) as a result, its net losses had substantially increased; 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.

Class Period

3/28/24 - 3/2/25

Deadline

May 13 2025

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40

Days Left

ZYXI

Zynex, Inc.

Deadline

May 19 2025

Class Period

3/13/23 - 3/11/25

Allegations

(1) Zynex shipped products, including electrodes, in excess of need; (2) as a result of this practice, the Company inflated its revenue; (3) the Company’s practice of filing false claims drew scrutiny from insurers, including the U.S. military health insurance program, Tricare; (4) as a result, it was reasonably likely that Zynex would face adverse consequences, including removal from insurer networks and penalties from the federal government; and (5) 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.

Class Period

3/13/23 - 3/11/25

Deadline

May 19 2025

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41

Days Left

SANA

Sana Biotechnology, Inc.

Deadline

May 20 2025

Class Period

3/17/23 - 11/4/24

Allegations

(i) Sana was at significant risk of having insufficient funds to maintain its current operations and advance one or more of its product candidates; (ii) SC291 in oncology, SC379, and SG299 were less promising than defendants had led investors to believe; (iii) in order to preserve cash and advance its more promising product candidates, Sana was likely to decrease funding for and/or discontinue SC291 in oncology, SC379, and SG299, as well as significantly reduce its headcount; (iv) accordingly, defendants overstated Sana’s financial capacity to maintain its current operations and advance its existing product candidates; and (v) as a result, defendants’ public statements were materially false and/or misleading at all relevant times.

Class Period

3/17/23 - 11/4/24

Deadline

May 20 2025

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41

Days Left

PPTA

Perpetua Resources Corp.

Deadline

May 20 2025

Class Period

4/17/24 - 2/13/25

Allegations

According to the complaint, defendants provided investors with material information concerning Perpetua’s expected initial capital expenditure for the Stibnite Gold Project. Defendants’ statements included, among other things, minimization of the impact of inflation and other potential sources for increased capital expenditure costs for the project. On February 13, 2025, Perpetua published an updated cash flow model for the Stibnite Gold Project, unveiling additional capital expenses of $952 million, a more than 75% increase from the original figures presented to investors and well beyond the suggested 10-20% increase contemplated by defendants. The Company attributed these increased costs on inflation, indirect costs, higher mining costs, and direct decisions defendants made with respect to the project, including the choice to change the design of the electrical poles from timber to steel and the decision to “buy-and-build instead of lease the oxygen plant.” Following this news, the price of Perpetua’s common stock declined dramatically. From a closing market price of $11.97 per share on February 13, 2025, Perpetua’s stock price fell to $9.29 per share on February 14, 2025, a decline of about 22.39% in the span of just a single day.

Class Period

4/17/24 - 2/13/25

Deadline

May 20 2025

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44

Days Left

UCTT

Ultra Clean Holdings, Inc.

Deadline

May 23 2025

Class Period

5/6/24 - 2/24/25

Allegations

According to the complaint, defendants provided investors with material information concerning the elevated demand from Chinese original equipment manufacturers (OEMs) and in the general Chinese domestic market for Ultra Clean’s products throughout the fiscal year 2024. Defendants’ statements included, among other things, reports of increased demand for the Company’s products and services in the domestic Chinese market and reports of increased revenue, including revenue doubling with no signs of slowing down, due to the elevated demand in China for Ultra Clean’s products and services. Defendants provided these 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 the demand for Ultra Clean’s products and services in the domestic Chinese market; notably, that the Company was facing a customer ramp issue with one of its critical customers, as well as a combination of inventory and demand corrections, which, ultimately, caused weakness for Ultra Clean in China. On February 24, 2025, Ultra Clean published fourth quarter and full year 2024 fiscal results and hosted an associated earnings call, where the Company’s executives revealed that Ultra Clean was facing “demand softness” in China. In particular, Ultra Clean was facing decreased demand in China due to extended qualification timelines and inventory absorption. Investors and analysts reacted immediately to these revelations. The price of Ultra Clean’s common stock declined dramatically. From a closing market price of $36.06 per share on February 24, 2025, Ultra Clean’s stock price fell to $25.90 per share on February 25, 2025, a decline of over 28% in the span a single day.

Class Period

5/6/24 - 2/24/25

Deadline

May 23 2025

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48

Days Left

ATNM

Actinium Pharmaceuticals, Inc.

Deadline

May 27 2025

Class Period

10/31/22 - 8/2/24

Allegations

(1) the Company’s data from the Phase 3 Sierra trial was unlikely to satisfy the FDA’s guidelines for the acceptance and approval of the Company’s targeted radiotherapy, Iomab-B BLA; (2) the additional analyses, including long-term follow-ups that purportedly demonstrated a trend towards improved Overall Survival that the Company provided to the FDA in an attempt to mitigate the Sierra Trial’s poor OS data were unlikely to satisfy the FDA’s guidelines for the acceptance and approval of the Company’s Iomab-B BLA; (3) as a result, the FDA would likely refuse to review the Iomab-B BLA or, if it did consider that BLA, that the application in its current form was unlikely to be approved; and (4), as a result, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

Class Period

10/31/22 - 8/2/24

Deadline

May 27 2025

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48

Days Left

SOUN

SoundHound AI, Inc.

Deadline

May 27 2025

Class Period

5/10/24 - 3/3/25

Allegations

(i) the material weaknesses in SoundHound’s internal controls over financial reporting impaired the Company’s ability to effectively account for corporate acquisitions; (ii) in addition, the Company overstated the extent to which it had remediated, and/or its ability to remediate, the material weaknesses in its internal controls over financial reporting; (iii) as a result of the foregoing material weaknesses, SoundHound’s reported goodwill following the Amelia Acquisition was inflated and would need to be corrected; (iv) further, SoundHound would likely require extra time and expense to effectively account for the SYNQ3 and Amelia Acquisitions; (v) the foregoing increased the risk that the Company would be unable to timely file certain financial reports with the SEC; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

5/10/24 - 3/3/25

Deadline

May 27 2025

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48

Days Left

SEI

Solaris Energy Infrastructure, Inc.

Deadline

May 27 2025

Class Period

7/9/24 - 3/17/25

Allegations

On March 17, 2025, Morpheus Research released a report alleging that the company’s Power Solutions division is built on an overvalued acquisition involving an individual with a history of environmental crimes. Additionally, the report raises concerns about potential overreliance on a single major customer, undisclosed environmental regulatory risks, and questionable financial reporting practices. Following this news, shares of Solaris Energy Infrastructure, Inc. fell over 15% in intraday trading on that day.

Class Period

7/9/24 - 3/17/25

Deadline

May 27 2025

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55

Days Left

CGC

Canopy Growth Corporation

Deadline

June 3 2025

Class Period

5/30/24 - 2/6/25

Allegations

(i) Canopy had incurred significant costs producing Claybourne pre-rolled joints in connection with the Claybourne product launch in Canada; (ii) the foregoing costs, in addition to certain indirect costs that Canopy incurred in connection with its Storz & Bickel vaporizer devices, were likely to have a significant negative impact on the Company’s gross margins and overall financial results; (iii) accordingly, defendants had overstated the efficacy of Canopy’s cost reduction measures and the health of its gross margins while downplaying issues with the same; and (iv) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

5/30/24 - 2/6/25

Deadline

June 3 2025

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55

Days Left

ECG

Everus Construction Group, Inc.

Deadline

June 3 2025

Class Period

10/31/24 - 2/11/25

Allegations

(1) the Company’s backlog conversion cycle had become elongated due to larger, more complex projects; (2) as a result, the Company’s revenue recognition would be delayed; and (3) 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.

Class Period

10/31/24 - 2/11/25

Deadline

June 3 2025

Learn More

55

Days Left

VTRS

Viatris Inc.

Deadline

June 3 2025

Class Period

8/8/24 - 2/26/25

Allegations

According to the complaint, defendants provided investors with material information concerning the failed inspection of Viatris’ Indore, India facility. Defendants’ statements misrepresented the FDA’s issuance of a warning letter and its impact on Viatris' operations. Defendants routinely referred to the impact of the warning letter as a mere “minor headwind” for the Company. On February 27, 2025, Viatris announced its financial results for the fourth quarter and full fiscal year 2024 and provided disappointing fiscal 2025 guidance. The Company attributed below-expectation guidance on “the expected financial impact from Indore facility warning letter and import alert.” Following this news, the price of Viatris’ common stock declined dramatically. From a closing market price of $11.24 per share on February 26, 2025, Viatris’ stock price fell to $9.53 per share on February 27, 2025, a decline of about 15.21% in the span of just a single day.

Class Period

8/8/24 - 2/26/25

Deadline

June 3 2025

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55

Days Left

ABBV

Cerevel Therapeutics Holdings, Inc.

Deadline

June 3 2025

Class Period

This lawsuit is on behalf of all persons or entities that: (a) sold or otherwise disposed of the publicly-traded common stock of Cerevel during the period from October 11, 2023 through August 1, 2024, inclusive. (b) held shares of Cerevel as of the January 8, 2024 record date and were entitled to vote on the merger of Cerevel and AbbVie Inc. (c) sold shares of Cerevel stock contemporaneously with Bain Capital’s purchase of shares on or about October 16, 2023.

Allegations

According to the complaint, Cerevel’s October 16, 2023 secondary stock offering (the “October Offering” or “Offering”) documents and other public statements omitted material facts regarding AbbVie’s interest in acquiring Cerevel at a price well in excess of the $22.81 per share Offering price, artificially deflating Cerevel’s stock price until the merger was announced. Moreover, Cerevel’s controlling shareholder, Bain Capital Investors, LLC (“Bain”), acquired Cerevel shares from the October Offering at an artificially depressed price while allegedly in possession of material nonpublic information regarding AbbVie’s interest. On December 6, 2023, Cerevel publicly announced that AbbVie agreed to acquire Cerevel for $45 per share. The merger allowed Bain to receive a windfall of more than $120 million on the shares it acquired at the artificially depressed Offering price. In addition, Cerevel’s January 18, 2024 Proxy statement misled investors regarding the true nature and timing of AbbVie’s interest in Cerevel.

Class Period

This lawsuit is on behalf of all persons or entities that: (a) sold or otherwise disposed of the publicly-traded common stock of Cerevel during the period from October 11, 2023 through August 1, 2024, inclusive. (b) held shares of Cerevel as of the January 8, 2024 record date and were entitled to vote on the merger of Cerevel and AbbVie Inc. (c) sold shares of Cerevel stock contemporaneously with Bain Capital’s purchase of shares on or about October 16, 2023.

Deadline

June 3 2025

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2

Days Left

ICLR

ICON Public Limited Company

Deadline

April 11 2025

Class Period

7/27/23 - 1/13/25

Allegations

(a)ICON was suffering from a material loss of business due to customer cost reduction measures and other widespread funding limitations impacting the Company’s client base; (b)ICON’s purported functional service provision and hybrid model offerings were insufficient to shield the Company from the adverse effects of a significant market downturn; (c) the requests for proposals ICON received from its biotechnology customers during the Class Period were used in substantial part as price discovery tools, and thus were not indicative of underlying client demand; (d)ICON’s customers had canceled contracts, limited or reduced engagements, delayed clinical trial work, and/or failed to enter into new contracts with ICON for additional clinical trial work at historical rates once existing projects ended (or were scheduled to end) in 2024; (e)ICON’s two largest customers were diversifying their clinical research organization providers away from the Company; (f)as a result of (a)-(e) above, ICON’s reported net new business awards and book-to-bill metrics materially misrepresented client demand for ICON’s services; and (g)as a result of (a)-(f) above, ICON was tracking materially below the 2024 revenue and EPS guidance issued during the Class Period and such guidance lacked a reasonable factual basis.

Class Period

7/27/23 - 1/13/25

Deadline

April 11 2025

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5

Days Left

ESTC

Elastic N.V.

Deadline

April 14 2025

Class Period

5/31/24 - 8/29/24

Allegations

(i) Elastic had implemented significant changes to its sales operations, particularly with respect to its customer segments in the Americas; (ii) the foregoing changes were likely to, and did, disrupt Elastic’s sales operations during the first quarter of its FY 2025; (iii) accordingly, defendants had overstated the stability of Elastic’s sales operations; (iv) as a result of all the foregoing, Elastic was unlikely to meet its own previously issued revenue guidance for its FY 2025; and (v) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

5/31/24 - 8/29/24

Deadline

April 14 2025

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5

Days Left

NTLA

Intellia Therapeutics, Inc.

Deadline

April 14 2025

Class Period

7/30/24 - 1/8/25

Allegations

According to the complaint, defendants provided investors with material information concerning Intellia's Phase 1/2 study evaluating NTLA-3001 for the treatment of alpha-1 antitrypsin deficiency (AATD)-associated lung disease. Defendants’ statements included, among other things, confidence in the Company’s timeline for the aforementioned study, specifically that Intellia expected to dose the first patient in the second half of 2024. Defendants failed to disclose inter alia that the demand for viral-based editing was rapidly dwindling as non-viral delivery methods became a main target of the scientific research community due to their cost-effectiveness and more efficient development, thus making NTLA-3001 an inefficient program for Intellia to maintain. The truth emerged on January 9, 2025, when Intellia published a press release announcing Company reorganization. In pertinent part, defendants disclosed that Intellia would be halting all NTLA-3001 research and studies and that the Company would be reducing its workforce by 27% in 2025. Specifically, the Company announced that management decided to focus Intellia’s resources on other pharmaceutical development and would be implementing cost saving in the form of a major reduction in force. As a result, defendants pipeline priority readjustment resulted in the Company’s once-touted NTLA-3001’s discontinuation. Following this news, Intellia’s stock price fell from a closing market price of $12.02 per share on January 8, 2025 to $10.20 per share on January 10, 2025.

Class Period

7/30/24 - 1/8/25

Deadline

April 14 2025

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5

Days Left

EIX

Edison International

Deadline

April 14 2025

Class Period

2/25/21 - 2/6/25

Allegations

(1) Edison’s claim that southern California Edison company used its public safety power shutoffs program to “proactively de-energize power lines to mitigate the risk of catastrophic wildfires during extreme weather events”, was false; (2) this resulted in heightened fire risk in California and heightened legal exposure to the Company; and (3) as a result, defendants’ statements about Edison’s business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all times.

Class Period

2/25/21 - 2/6/25

Deadline

April 14 2025

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5

Days Left

MRK

Merck & Co., Inc.

Deadline

April 14 2025

Class Period

2/3/22 - 2/3/25

Allegations

According to the complaint, defendants provided investors with material information concerning Merck’s expected revenue of $11 billion from sales of Gardasil by 2030. Defendants’ statements included, among other things, confidence in Merck’s purported ability to utilize successful consumer activation and education efforts on the benefits of Gardasil in order to drive demand and capitalize on eligible populations for vaccination, resulting in confidently optimistic reports and forecasts of Gardasil’s growth in China. The full truth finally emerged on February 4, 2025, when Merck announced it would no longer achieve the long-forecasted $11 billion in sales of Gardasil by 2030, as it would cease shipments of Gardasil to China “through at least midyear” to facilitate a “rapid reduction of inventory.” Defendants claimed this was necessitated by the continued over-inflation of overall channel inventories as demand in China for Gardasil had “not recovered to the level we had expected.” Following this news, Merck’s common stock declined dramatically. From a closing market price of $99.79 per share on February 3, 2025, Merck’s stock price fell to $90.74 per share on February 4, 2025, a decline of more than 9% in the span of just a single day.

Class Period

2/3/22 - 2/3/25

Deadline

April 14 2025

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5

Days Left

FMC

FMC Corporation

Deadline

April 14 2025

Class Period

11/16/23 - 2/4/25

Allegations

(1) the Company’s channel management initiatives were not progressing as represented; (2) faced with pricing pressure, the Company had made the decision not to compete on prices and instead walk away from sales opportunities; (3) the Company had inflated inventory in the channels in “Latin America, including Brazil, Asia, including India, as well as Canada and Eastern Europe;” 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.

Class Period

11/16/23 - 2/4/25

Deadline

April 14 2025

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6

Days Left

TMDX

TransMedics Group, Inc.

Deadline

April 15 2025

Class Period

2/28/23 - 1/10/25

Allegations

(1) TransMedics used kickbacks, fraudulent overbilling, and coercive tactics to generate business and revenue; (2) TransMedics engaged in unsafe practices and hid safety issues and generally lacked safety oversight; (3) the foregoing subjected TransMedics to heightened risk of scrutiny and regulatory risk; and (4) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

Class Period

2/28/23 - 1/10/25

Deadline

April 15 2025

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6

Days Left

ALAR

Alarum Technologies Ltd.

Deadline

April 15 2025

Class Period

3/14/24 - 8/26/24

Allegations

(i) the Company was less effective in retaining and/or expanding customer engagements than it had represented to investors; (ii) the foregoing would impair Alarum’s ability to generate consistent revenue growth; (iii) accordingly, Alarum’s business and/or financial prospects were overstated; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

3/14/24 - 8/26/24

Deadline

April 15 2025

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9

Days Left

VG

Venture Global, Inc.

Deadline

April 18 2025

Class Period

This lawsuit is on behalf of all shareholders that purchased stock pursuant and/or traceable to Venture’s registration statement for the initial public offering held on or about January 24, 2025.

Allegations

According to the complaint, Venture completed its initial public offering on January 27, 2025, selling 70 million shares at $24.00 per share. On February 5, 2025, TotalEnergies, an energy company that was a target customer of Venture, rejected opportunities to become a long-term customer of Venture, citing lack of trust. In particular, TotalEnergies CEO, stated that he was approached by Venture to see if the company would be interested in a long-term supply contract for liquefied natural gas from the Calcasieu Pass terminal in Louisiana, but he rejected the offer “because of what they are doing.” Venture is currently facing legal challenges from existing large clients, such as BP and Shell, due to delays in supply contracts as Venture commissions its projects. Given the fact that defendants ability to deliver liquefied natural gas (LNG) to the world and to continue development of Venture’s five natural gas liquefication and export projects depends on customer contracts, defendants’ failure to account for and address these issues caused statements in Venture’s registration statement to be false and/or materially misleading at the time of the initial public offering.

Class Period

This lawsuit is on behalf of all shareholders that purchased stock pursuant and/or traceable to Venture’s registration statement for the initial public offering held on or about January 24, 2025.

Deadline

April 18 2025

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12

Days Left

STZ

Constellation Brands, Inc.

Deadline

April 21 2025

Class Period

4/11/24 - 1/8/25

Allegations

According to the complaint, defendants provided investors with material information concerning Constellation’s full year 2024 fiscal results and financial outlook for 2025 which was based in material part on defendants enhanced focus on improving mix, inventory and sales execution in its Wine and Spirits business, specifically focusing efforts within its premium and above brands to drive more consistent growth. Additionally, defendants made investments in media spend and price promotions as well as adjustments in sales capabilities to support distributor partners. On January 8, 2025 defendants issued a press release announcing the Company’s third quarter fiscal year 2025 results. In pertinent part, defendants presented a significant miss on sales performance in the Beer segment and an even steeper miss for the Wine & Spirits. Following this news, the price of Constellation’s common stock declined dramatically. From a closing market price of $219.28 per share on January 8, 2025 to $181.81 per share on January 10, 2025.

Class Period

4/11/24 - 1/8/25

Deadline

April 21 2025

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12

Days Left

TTD

The Trade Desk, Inc.

Deadline

April 21 2025

Class Period

5/9/24 - 2/12/25

Allegations

(1) Trade Desk was experiencing significant, ongoing, self-inflicted execution challenges rolling out the Company's AI forecasting tool, Kokai, including transitioning clients to Kokai from the Company’s older platform Solimar; (2) such execution challenges meaningfully delayed the Kokai Rollout; (3) Trade Desk’s inability to effectively execute the Kokai Rollout negatively impacted the Company’s business and operations, particularly revenue growth; and (4) as a result of the above, Defendants’ positive statements about the Company’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

Class Period

5/9/24 - 2/12/25

Deadline

April 21 2025

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13

Days Left

SMTC

Semtech Corporation

Deadline

April 22 2025

Class Period

8/27/24 - 2/7/25

Allegations

(1) its CopperEdge products did not meet the needs of its server rack customer or end users; (2) as a result, the CopperEdge products required certain rack architecture changes; (3) as a result of the foregoing, the Company’s sales of CopperEdge products would not ramp-up during fiscal 2026; (4) as a result, sales of CopperEdge products would be lower-than-expected; and (5) 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.

Class Period

8/27/24 - 2/7/25

Deadline

April 22 2025

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14

Days Left

ATKR

Atkore Inc.

Deadline

April 23 2025

Class Period

2/1/24 - 2/3/25

Allegations

(1) Atkore engaged in an anticompetitive price-fixing scheme that artificially inflated the price of PVC Pipes; (2) Atkore reaped significant, unsustainable financial benefits from its anticompetitive conduct; (3) as Atkore’s price-fixing scheme was exposed, the Company and its price-fixing co-conspirators were no longer able to artificially inflate the price of PVC Pipes, resulting in a substantial decrease in the price of PVC Pipes; (4) Atkore’s business and operations were negatively impacted; and (5) as a result, defendants’ positive statements Company’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

Class Period

2/1/24 - 2/3/25

Deadline

April 23 2025

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19

Days Left

QUBT

Quantum Computing Inc.

Deadline

April 28 2025

Class Period

3/30/20 - 1/15/25

Allegations

(i) defendants overstated the capabilities of QCI’s quantum computing technologies, products, and/or services; (ii) defendants overstated the scope and nature of QCI’s relationship with NASA, as well as the scope and nature of QCI’s NASA-related contracts and/or subcontracts; (iii) defendants overstated QCI’s progress in developing a thin film lithium niobate, TFLN foundry, the scale of the purported TFLN foundry, and orders for the Company’s TFLN chips; (iv) QCI’s business dealings with Quad M and millionways both qualified as related party transactions; (v) accordingly, QCI’s revenues relied, at least in part, on undisclosed related party transactions; (vi) all the foregoing, once revealed, was likely to have a significant negative impact on QCI’s business and reputation; and (vii) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

3/30/20 - 1/15/25

Deadline

April 28 2025

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19

Days Left

MANH

Manhattan Associates, Inc.

Deadline

April 28 2025

Class Period

10/22/24 - 1/28/25

Allegations

According to the complaint, defendants provided investors with material information concerning Manhattan Associates’ expected revenue for the fiscal year 2025. Defendants’ statements included, among other things, confidence in the Company’s ability to forecast guidance despite macroeconomic fluctuations, the growth potential of their professional services offerings, and the ability for their cloud revenue to drive revenue for its professional services. On January 28, 2025, Manhattan Associates published its financial results for the fourth quarter and full fiscal year 2024 and announced reduced revenue guidance for the full fiscal year 2025. The Company attributed its results and lowered guidance on the “shift in professional services work to future periods . . . and to a lesser extent, reduced customization and higher partner utilization.” Following this news, the price of Manhattan Associates’ common stock declined dramatically from a closing market price of $295.10 per share on January 28, 2025, to $222.84 per share on January 29, 2025, a decline of about 24.49% in the span of just a single day.

Class Period

10/22/24 - 1/28/25

Deadline

April 28 2025

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19

Days Left

RKLB

Rocket Lab USA, Inc.

Deadline

April 28 2025

Class Period

11/12/24 - 2/25/25

Allegations

(1) the Company’s plans for three barge landing tests were significantly delayed; (2) a critical potable water problem was not scheduled to be fixed until January 2026, which delayed preparation of the launch pad; (3) as a result of the foregoing, there was a substantial risk that Rocket Lab’s Neutron rocket would not launch in mid-2025; (4) Neutron’s only contract was made at a discount with an unreliable partner; and (5) 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.

Class Period

11/12/24 - 2/25/25

Deadline

April 28 2025

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26

Days Left

ELF

e.l.f. Beauty, Inc.

Deadline

May 5 2025

Class Period

11/1/23 - 11/19/24

Allegations

(i) contrary to its representations to investors, the Company was experiencing rising inventory levels as a consequence of flagging sales; (ii) Elf falsely attributed the rising inventory levels to, among other things, changes in its sourcing practices; (iii) to maintain investor confidence, Elf reported inflated revenue, profits, and inventory over several quarters; (iv) the Company’s business and/or financial prospects were overstated; (v) all of the foregoing, once revealed, would likely have a material negative impact on the Company; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

11/1/23 - 11/19/24

Deadline

May 5 2025

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26

Days Left

SWKS

Skyworks Solutions, Inc.

Deadline

May 5 2025

Class Period

7/30/24 - 2/5/25

Allegations

According to the complaint, defendants provided investors with material information concerning Skyworks’ expected revenue for the fiscal year 2025. Defendants’ statements included, among other things, confidence in Skyworks’ ability to expand its mobile business and capitalize on its growth potential by investing in new technologies to diversify its portfolio of offerings. On February 5, 2025, after market close, Skyworks announced its financial results for the first quarter of fiscal year 2025 and provided lower-than anticipated revenue guidance for the second quarter of fiscal year 2025. The Company attributed its results and low guidance to a “competitive landscape” that had “intensified” in recent years. Following this news, the price of Skyworks’ common stock declined dramatically. From a closing market price of $87.08 per share on February 5, 2025, Skyworks’ stock price fell to $65.60 per share on February 6, 2025, a decline of over 24% in the span of just a single day.

Class Period

7/30/24 - 2/5/25

Deadline

May 5 2025

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26

Days Left

APP

AppLovin Corporation

Deadline

May 5 2025

Class Period

5/10/23 - 2/25/25

Allegations

According to the complaint, defendants provided investors with material information concerning AppLovin’s financial growth and stability. Defendants’ statements included, among other things, confidence in AppLovin’s launch of its AXON 2.0 digital ad platform and using “cutting-edge AI technologies” to more efficiently match advertisements to mobile games, in addition to expanding into web-based marketing and e-commerce. Moreover, defendants publicly reported impressive financial results, outlooks, and guidance to investors, all while using dishonest advertising practices. The truth emerged on February 26, 2025, when analyst research reports emerged stating that AppLovin was reverse engineering and exploiting advertising data from Meta Platforms. The reports further alleged AppLovin was utilizing manipulative practices to artificially inflate their own ad click-through and app download rates, such as by having ads click on themselves or utilizing design gimmicks to trigger forced shadow downloads, erroneously inflating installation numbers and, in turn, its profit figures. Following this news, the price of AppLovin’s stock declined from $377.06 per share on February 25, 2025 to $331.00 per share on February 26, 2025.

Class Period

5/10/23 - 2/25/25

Deadline

May 5 2025

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26

Days Left

MRVI

Maravai LifeSciences Holdings, Inc.

Deadline

May 5 2025

Class Period

8/7/24 - 2/24/25

Allegations

(1) Maravai lacked adequate internal controls over financial reporting related to revenue recognition; (2) as a result, the Company inaccurately recognized revenue on certain transactions during fiscal 2024; (3) its goodwill was overstated; 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.

Class Period

8/7/24 - 2/24/25

Deadline

May 5 2025

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26

Days Left

RC

Ready Capital Corporation

Deadline

May 5 2025

Class Period

11/7/24 - 3/2/25

Allegations

(1) significant non-performing loans in its CRE portfolio were not likely to be collectible; (2) Ready Capital would fully reserve these problem loans in order to “stabilize” its CRE portfolio; (3) this was not accurately reflected in Ready Capital’s current expected credit loss or valuation allowances; (4) as a result, the Company’s financial results would be adversely affected; and (5), 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.

Class Period

11/7/24 - 3/2/25

Deadline

May 5 2025

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30

Days Left

NEP

XPLR Infrastructure, LP

Deadline

May 9 2025

Class Period

1/26/21 - 1/27/25

Allegations

(i) XPLR was struggling to maintain its operations as a yieldco; (ii) defendants temporarily relieved this issue by entering into CEPF, convertible equity portfolio financing arrangements while downplaying the attendant risks; (iii) XPLR could not buy out CEPFs before their maturity date without risking significant unitholder dilution; (iv) as a result, defendants planned to halt cash distributions to investors and instead redirect those funds to, inter alia, buy out the Company’s CEPFs; (v) as a result of all the foregoing, XPLR’s yieldco business model and distribution growth rate was unsustainable; and (vi) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

1/26/21 - 1/27/25

Deadline

May 9 2025

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33

Days Left

FLNC

Fluence Energy, Inc.

Deadline

May 12 2025

Class Period

11/29/23 - 2/10/25

Allegations

(1) Fluence’s relationship with its founders and largest sources of revenue, Siemens AG and The AES Corporation, was poised to decline; (2) Siemens Energy, Siemens AG’s U.S. affiliate, had accused the Company of engineering failures and fraud; (3) Fluence’s margins and revenue growth were inflated as Siemens and AES were moving to divest; and (4) based on the foregoing, defendants lacked a reasonable basis for their positive statements related to Fluence’s battery energy storage business, as well as related financial results, growth, and prospects.

Class Period

11/29/23 - 2/10/25

Deadline

May 12 2025

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33

Days Left

GERN

Geron Corporation

Deadline

May 12 2025

Class Period

6/7/24 - 2/25/25

Allegations

According to the complaint, defendants provided investors with material information concerning defendants’ expectations for the launch and growth potential of Rytelo (imetelstat). Defendants’ statements included, among other things, confidence in Geron’s ability to capitalize on the purportedly significant unmet need for the drug and to execute on its commercial plan to target first-line ESA ineligible patients, while continually minimizing the risks associated with the burden of the weekly monitoring requirement for Rytelo and the impacts of seasonality and existing competition on the drug’s sales. On February 26, 2025, Geron announced its financial results for the fourth quarter of fiscal 2024, disclosing that Rytelo’s growth had flattened over the preceding months. The Company attributed the diminished growth on seasonality, competition, lack of awareness for Rytelo, and the burden of the monitoring requirement necessary for the drug treatment. Following this news, the price of Geron’s common stock declined dramatically. From a closing market price of $2.37 per share on February 25, 2025, Geron’s stock price fell to $1.61 per share on February 26, 2025, a decline of about 32.07% in the span of just a single day.

Class Period

6/7/24 - 2/25/25

Deadline

May 12 2025

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34

Days Left

TFII

TFI International Inc.

Deadline

May 13 2025

Class Period

4/26/24 - 2/19/25

Allegations

(1) the Company was losing small and medium business customers; (2) as a result, the Company’s TForce revenue was declining; (3) TFI was experiencing difficulties managing its costs; (4) as a result of the foregoing, the profitability of its largest business segment was declining; and (5) 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.

Class Period

4/26/24 - 2/19/25

Deadline

May 13 2025

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34

Days Left

EU

enCore Energy Corp.

Deadline

May 13 2025

Class Period

3/28/24 - 3/2/25

Allegations

(1) enCore lacked effective internal controls over financial reporting; (2) enCore could not capitalize certain exploratory and development costs under GAAP; (3) as a result, its net losses had substantially increased; 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.

Class Period

3/28/24 - 3/2/25

Deadline

May 13 2025

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40

Days Left

ZYXI

Zynex, Inc.

Deadline

May 19 2025

Class Period

3/13/23 - 3/11/25

Allegations

(1) Zynex shipped products, including electrodes, in excess of need; (2) as a result of this practice, the Company inflated its revenue; (3) the Company’s practice of filing false claims drew scrutiny from insurers, including the U.S. military health insurance program, Tricare; (4) as a result, it was reasonably likely that Zynex would face adverse consequences, including removal from insurer networks and penalties from the federal government; and (5) 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.

Class Period

3/13/23 - 3/11/25

Deadline

May 19 2025

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41

Days Left

SANA

Sana Biotechnology, Inc.

Deadline

May 20 2025

Class Period

3/17/23 - 11/4/24

Allegations

(i) Sana was at significant risk of having insufficient funds to maintain its current operations and advance one or more of its product candidates; (ii) SC291 in oncology, SC379, and SG299 were less promising than defendants had led investors to believe; (iii) in order to preserve cash and advance its more promising product candidates, Sana was likely to decrease funding for and/or discontinue SC291 in oncology, SC379, and SG299, as well as significantly reduce its headcount; (iv) accordingly, defendants overstated Sana’s financial capacity to maintain its current operations and advance its existing product candidates; and (v) as a result, defendants’ public statements were materially false and/or misleading at all relevant times.

Class Period

3/17/23 - 11/4/24

Deadline

May 20 2025

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41

Days Left

PPTA

Perpetua Resources Corp.

Deadline

May 20 2025

Class Period

4/17/24 - 2/13/25

Allegations

According to the complaint, defendants provided investors with material information concerning Perpetua’s expected initial capital expenditure for the Stibnite Gold Project. Defendants’ statements included, among other things, minimization of the impact of inflation and other potential sources for increased capital expenditure costs for the project. On February 13, 2025, Perpetua published an updated cash flow model for the Stibnite Gold Project, unveiling additional capital expenses of $952 million, a more than 75% increase from the original figures presented to investors and well beyond the suggested 10-20% increase contemplated by defendants. The Company attributed these increased costs on inflation, indirect costs, higher mining costs, and direct decisions defendants made with respect to the project, including the choice to change the design of the electrical poles from timber to steel and the decision to “buy-and-build instead of lease the oxygen plant.” Following this news, the price of Perpetua’s common stock declined dramatically. From a closing market price of $11.97 per share on February 13, 2025, Perpetua’s stock price fell to $9.29 per share on February 14, 2025, a decline of about 22.39% in the span of just a single day.

Class Period

4/17/24 - 2/13/25

Deadline

May 20 2025

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44

Days Left

UCTT

Ultra Clean Holdings, Inc.

Deadline

May 23 2025

Class Period

5/6/24 - 2/24/25

Allegations

According to the complaint, defendants provided investors with material information concerning the elevated demand from Chinese original equipment manufacturers (OEMs) and in the general Chinese domestic market for Ultra Clean’s products throughout the fiscal year 2024. Defendants’ statements included, among other things, reports of increased demand for the Company’s products and services in the domestic Chinese market and reports of increased revenue, including revenue doubling with no signs of slowing down, due to the elevated demand in China for Ultra Clean’s products and services. Defendants provided these 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 the demand for Ultra Clean’s products and services in the domestic Chinese market; notably, that the Company was facing a customer ramp issue with one of its critical customers, as well as a combination of inventory and demand corrections, which, ultimately, caused weakness for Ultra Clean in China. On February 24, 2025, Ultra Clean published fourth quarter and full year 2024 fiscal results and hosted an associated earnings call, where the Company’s executives revealed that Ultra Clean was facing “demand softness” in China. In particular, Ultra Clean was facing decreased demand in China due to extended qualification timelines and inventory absorption. Investors and analysts reacted immediately to these revelations. The price of Ultra Clean’s common stock declined dramatically. From a closing market price of $36.06 per share on February 24, 2025, Ultra Clean’s stock price fell to $25.90 per share on February 25, 2025, a decline of over 28% in the span a single day.

Class Period

5/6/24 - 2/24/25

Deadline

May 23 2025

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48

Days Left

ATNM

Actinium Pharmaceuticals, Inc.

Deadline

May 27 2025

Class Period

10/31/22 - 8/2/24

Allegations

(1) the Company’s data from the Phase 3 Sierra trial was unlikely to satisfy the FDA’s guidelines for the acceptance and approval of the Company’s targeted radiotherapy, Iomab-B BLA; (2) the additional analyses, including long-term follow-ups that purportedly demonstrated a trend towards improved Overall Survival that the Company provided to the FDA in an attempt to mitigate the Sierra Trial’s poor OS data were unlikely to satisfy the FDA’s guidelines for the acceptance and approval of the Company’s Iomab-B BLA; (3) as a result, the FDA would likely refuse to review the Iomab-B BLA or, if it did consider that BLA, that the application in its current form was unlikely to be approved; and (4), as a result, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

Class Period

10/31/22 - 8/2/24

Deadline

May 27 2025

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48

Days Left

SOUN

SoundHound AI, Inc.

Deadline

May 27 2025

Class Period

5/10/24 - 3/3/25

Allegations

(i) the material weaknesses in SoundHound’s internal controls over financial reporting impaired the Company’s ability to effectively account for corporate acquisitions; (ii) in addition, the Company overstated the extent to which it had remediated, and/or its ability to remediate, the material weaknesses in its internal controls over financial reporting; (iii) as a result of the foregoing material weaknesses, SoundHound’s reported goodwill following the Amelia Acquisition was inflated and would need to be corrected; (iv) further, SoundHound would likely require extra time and expense to effectively account for the SYNQ3 and Amelia Acquisitions; (v) the foregoing increased the risk that the Company would be unable to timely file certain financial reports with the SEC; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

5/10/24 - 3/3/25

Deadline

May 27 2025

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48

Days Left

SEI

Solaris Energy Infrastructure, Inc.

Deadline

May 27 2025

Class Period

7/9/24 - 3/17/25

Allegations

On March 17, 2025, Morpheus Research released a report alleging that the company’s Power Solutions division is built on an overvalued acquisition involving an individual with a history of environmental crimes. Additionally, the report raises concerns about potential overreliance on a single major customer, undisclosed environmental regulatory risks, and questionable financial reporting practices. Following this news, shares of Solaris Energy Infrastructure, Inc. fell over 15% in intraday trading on that day.

Class Period

7/9/24 - 3/17/25

Deadline

May 27 2025

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55

Days Left

CGC

Canopy Growth Corporation

Deadline

June 3 2025

Class Period

5/30/24 - 2/6/25

Allegations

(i) Canopy had incurred significant costs producing Claybourne pre-rolled joints in connection with the Claybourne product launch in Canada; (ii) the foregoing costs, in addition to certain indirect costs that Canopy incurred in connection with its Storz & Bickel vaporizer devices, were likely to have a significant negative impact on the Company’s gross margins and overall financial results; (iii) accordingly, defendants had overstated the efficacy of Canopy’s cost reduction measures and the health of its gross margins while downplaying issues with the same; and (iv) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

5/30/24 - 2/6/25

Deadline

June 3 2025

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55

Days Left

ECG

Everus Construction Group, Inc.

Deadline

June 3 2025

Class Period

10/31/24 - 2/11/25

Allegations

(1) the Company’s backlog conversion cycle had become elongated due to larger, more complex projects; (2) as a result, the Company’s revenue recognition would be delayed; and (3) 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.

Class Period

10/31/24 - 2/11/25

Deadline

June 3 2025

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55

Days Left

VTRS

Viatris Inc.

Deadline

June 3 2025

Class Period

8/8/24 - 2/26/25

Allegations

According to the complaint, defendants provided investors with material information concerning the failed inspection of Viatris’ Indore, India facility. Defendants’ statements misrepresented the FDA’s issuance of a warning letter and its impact on Viatris' operations. Defendants routinely referred to the impact of the warning letter as a mere “minor headwind” for the Company. On February 27, 2025, Viatris announced its financial results for the fourth quarter and full fiscal year 2024 and provided disappointing fiscal 2025 guidance. The Company attributed below-expectation guidance on “the expected financial impact from Indore facility warning letter and import alert.” Following this news, the price of Viatris’ common stock declined dramatically. From a closing market price of $11.24 per share on February 26, 2025, Viatris’ stock price fell to $9.53 per share on February 27, 2025, a decline of about 15.21% in the span of just a single day.

Class Period

8/8/24 - 2/26/25

Deadline

June 3 2025

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55

Days Left

ABBV

Cerevel Therapeutics Holdings, Inc.

Deadline

June 3 2025

Class Period

This lawsuit is on behalf of all persons or entities that: (a) sold or otherwise disposed of the publicly-traded common stock of Cerevel during the period from October 11, 2023 through August 1, 2024, inclusive. (b) held shares of Cerevel as of the January 8, 2024 record date and were entitled to vote on the merger of Cerevel and AbbVie Inc. (c) sold shares of Cerevel stock contemporaneously with Bain Capital’s purchase of shares on or about October 16, 2023.

Allegations

According to the complaint, Cerevel’s October 16, 2023 secondary stock offering (the “October Offering” or “Offering”) documents and other public statements omitted material facts regarding AbbVie’s interest in acquiring Cerevel at a price well in excess of the $22.81 per share Offering price, artificially deflating Cerevel’s stock price until the merger was announced. Moreover, Cerevel’s controlling shareholder, Bain Capital Investors, LLC (“Bain”), acquired Cerevel shares from the October Offering at an artificially depressed price while allegedly in possession of material nonpublic information regarding AbbVie’s interest. On December 6, 2023, Cerevel publicly announced that AbbVie agreed to acquire Cerevel for $45 per share. The merger allowed Bain to receive a windfall of more than $120 million on the shares it acquired at the artificially depressed Offering price. In addition, Cerevel’s January 18, 2024 Proxy statement misled investors regarding the true nature and timing of AbbVie’s interest in Cerevel.

Class Period

This lawsuit is on behalf of all persons or entities that: (a) sold or otherwise disposed of the publicly-traded common stock of Cerevel during the period from October 11, 2023 through August 1, 2024, inclusive. (b) held shares of Cerevel as of the January 8, 2024 record date and were entitled to vote on the merger of Cerevel and AbbVie Inc. (c) sold shares of Cerevel stock contemporaneously with Bain Capital’s purchase of shares on or about October 16, 2023.

Deadline

June 3 2025

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