The filed complaint alleges that RCI Hospitality Holdings, Inc. made materially false and/or misleading statements and/or failed to disclose that: (1) defendants engaged in tax fraud; (2) defendants committed bribery to cover up the fact that they committed tax fraud; (3) as a result, defendants understated the legal risk facing the Company; 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.