The filed complaint alleges that Upstart, Inc. made materially false and/or misleading statements and/or failed to disclose that: (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