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Settlements

$24.6 Million

Loma Negra Industrial Argentina Sociedad Argentina

$14 Million

Corcept Therapeutics Incorporated

$9.5 Million

Babcock & Wilcox Enterprises, Inc.

$40 Million

U.S. Steel

$7 Million

Aqua Metals, Inc.

$7.025 Million

WideOpenWest, Inc.

$8.25 Million

Helios and Matheson Analytics Inc.

$13.85 Million

Illumina, Inc.

$14.5 Million

Avon Products Inc.

I think you’ve done a superb job and I really appreciate the way this case was handled.

The Honorable Ronald B. Rubin in Teoh v. Ferrantino, C.A. No. 356627 (Cir. Ct. for Montgomery Cnty., MD 2012)

…a model for how [the] great legal profession should conduct itself.

Justice Timothy S. Driscoll in Grossman v. State Bancorp, Inc., Index No. 600469/2011 (N.Y. Sup. Ct. Nassau Cnty. Nov. 29, 2011)

I find the firm to be well-qualified to serve as Lead Counsel.

The Honorable Andrew L. Carter, Jr. In Snyder v. Baozun Inc., No. 1:19-CV-11290 (S.D.N.Y. Sept. 8, 2020)

In appointing the Firm Lead Counsel, the Honorable Analisa Torres noted our “extensive experience” in securities litigation.

White Pine Invs. v. CVR Ref., LP, No. 20 CIV. 2863 (S.D.N.Y. Jan. 5, 2021)

Class Counsel have demonstrated that they are skilled in this area of the law and therefore adequate to represent the Settlement Class as well.

Furthermore, with the increasing importance of compliance and risk management, kyc for law firms has become an essential component of legal services.

The Honorable Barry Ted Moskowitz in In re Regulus Therapeutics Inc. Sec. Litig., No. 3:17-CV-182-BTM-RBB (S.D. Cal. Oct. 30, 2020)

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Upcoming Deadlines

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2

Days Left

MDB

MongoDB, Inc.

Deadline

September 9 2024

Class Period

8/31/23 - 5/30/24

Allegations

According to the complaint, on March 7, 2024, MongoDB reported strong Q4 2024 results and then announced lower than expected full-year guidance for 2025. MongoDB attributed it to the Company’s change in its “sales incentive structure” which led to a decrease in revenue related to “unused commitments and multi-year licensing deals.” Following this news, MongoDB’s stock price fell by $28.59 per share to close at $383.42 per share. Later, on May 30, 2024, MongoDB further lowered its guidance for the full year 2025 attributing it to “macro impacting consumption growth.” Analysts commenting on the reduced guidance questioned if changes made to the Company’s marketing strategy “led to change in customer behavior and usage patterns.” Following this news, MongoDB’s stock price fell by $73.94 per share to close at $236.06 per share.

Class Period

8/31/23 - 5/30/24

Deadline

September 9 2024

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3

Days Left

WBA

Walgreens Boots Alliance, Inc.

Deadline

September 10 2024

Class Period

10/12/23 - 6/26/24

Allegations

According to the complaint, on June 27, 2024, Walgreens announced 3Q24 financial results and reduced its revenue guidance for the fourth quarter and full fiscal year 2024. The Company attributed its results and lowered guidance on the “significant challenges in the U.S. Retail Pharmacy business stemming from a worse-than-expected consumer environment and challenging pharmacy industry trends.” Following this news, Walgreens stock began trading more than 20% lower than the previous day’s closing price of $15.65 per share.

Class Period

10/12/23 - 6/26/24

Deadline

September 10 2024

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3

Days Left

CVS

CVS Health Corporation

Deadline

September 10 2024

Class Period

5/3/23 - 4/30/24

Allegations

(i) the forecasts CVS used to determine plan premiums were ineffective at accounting for medical cost trends and health care utilization patterns; (ii) as a result, CVS was likely to incur significant expenses to cover cost increases that were not accounted for in the Company’s forecasts and thus not covered by plan premiums; (iii) accordingly, CVS had overstated the profitability of its health care benefits segment; (iv) contrary to defendants’ assurances, the revenues generated from the Company’s other primary segments were insufficient to offset the negative financial impact of the increasing expenditures within the health care benefits segment; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

5/3/23 - 4/30/24

Deadline

September 10 2024

Learn More

9

Days Left

AAL

American Airlines Group Inc.

Deadline

September 16 2024

Class Period

1/25/24 - 5/28/24

Allegations

During the class period, defendants made overwhelmingly positive statements to investors regarding American’s new sales and distribution strategy to reduce internal expenses while simultaneously driving a significant demand increase for the Company’s airline services. The complaint alleges that these statements misrepresented the true state of American, and that the Company was simultaneously concealing material adverse facts including, notably, that the Company’s sales and distribution strategy was not driving the revenue projected.

Class Period

1/25/24 - 5/28/24

Deadline

September 16 2024

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9

Days Left

CAE

CAE Inc.

Deadline

September 16 2024

Class Period

2/11/22 - 5/21/24

Allegations

(i) several of CAE’s pre-COVID fixed-price defense contracts had incurred severe cost overruns due to supply chain and labor issues – as the segment was significantly impacted by the pandemic – which dented the segment’s profit and operating margin; and (ii) CAE failed to successfully reduce hard costs and achieve a sufficient level of operational efficiency, particularly with respect to such contracts, necessitating a re-baselining of the defense business and significant associated charges.

Class Period

2/11/22 - 5/21/24

Deadline

September 16 2024

Learn More

10

Days Left

ODD

ODDITY Tech Ltd.

Deadline

September 17 2024

Class Period

7/19/23 - 5/20/24

Allegations

(i) Oddity overstated its AI technology and capabilities, and/or the extent to which this technology drove the Company’s sales; (ii) Oddity’s repeat purchase rates and revenues were, at least in part, derived from unsustainable and deceptive sales and advertising practices; (iii) Oddity downplayed the true scope and severity of ongoing civil litigation against the Company and/or its subsidiaries; and (iv) as a result, Oddity’s public statements were materially false and misleading at all relevant times.

Class Period

7/19/23 - 5/20/24

Deadline

September 17 2024

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16

Days Left

VICR

Vicor Corporation

Deadline

September 23 2024

Class Period

4/26/23 - 2/22/24

Allegations

During the class period, Defendants created the false and/or materially misleading impression that Vicor had secured a significant deal for its H100 product that, according to analysts, was Nvidia Corporation. These statements proved incorrect when first, on October 24, 2023, Vicor conspicuously failed to discuss the deal and then later, on February 22, 2024, when the Company issued a press release announcing its end of year earnings and flagged a sharp reversal in new contracts and sales. From an intra-class period high of nearly $100/share, Vicor’s stock price has fallen approximately 60%.

Class Period

4/26/23 - 2/22/24

Deadline

September 23 2024

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17

Days Left

MGNX

MacroGenics, Inc.

Deadline

September 24 2024

Class Period

3/7/24 - 5/9/24

Allegations

During the class period, Defendants made material misrepresentations about the safety data from its TAMARACK Phase 2 study of vobramitamab duocarmazine. On May 9, 2024, the investing public learned that the drug was significantly more dangerous than defendants had previously represented. Following this news, MGNX’s stock declined 77.4% due to a drop of $11.36/share.

Class Period

3/7/24 - 5/9/24

Deadline

September 24 2024

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23

Days Left

ABR

Arbor Realty Trust, Inc.

Deadline

September 30 2024

Class Period

5/7/21 - 7/11/24

Allegations

According to the complaint, during the class period, defendants provided investors with false and/or materially misleading information concerning ABR’s operational and financial health, including its balance sheet loan book and net interest income. Over the course of several months, shareholders learned the truth when first, on March 14, 2023, and then again, on December 5, 2023, investment firms published research reports concerning ABR’s real estate portfolio and accusing the Company of hiding toxic assets. On July 12, 2024, Bloomberg reported that federal prosecutors and the Federal Bureau of Investigation were probing ABR over its lending practices and the value of its loan book. In connection with these disclosures, the price of ABR’s stock has declined substantially causing damages to investors, including most recently the decline from $15.53 per share to $12.89 per share following the Bloomberg report.

Class Period

5/7/21 - 7/11/24

Deadline

September 30 2024

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23

Days Left

FIVE

Five Below, Inc.

Deadline

September 30 2024

Class Period

3/20/24 - 7/16/24

Allegations

According to the complaint, defendants provided investors with false and/or materially misleading information about FIVE’s financial strength and operations, including its outlook for the first quarter and full year 2024. This information included FIVE’s statement that net sales are expected to be in the range of $826 million to $846 million based on opening approximately 55 to 60 new stores in the first quarter. Further, FIVE claimed that net sales for the full year are expected to be in the range of $3.97 billion to $4.07 billion based on opening between 225 and 235 new stores. Investors discovered that these statements were false and/or materially misleading when, on June 5, 2024, FIVE announced disappointing first quarter 2024 sales result and cut its full year 2024 guidance stating, “Net sales are expected to be in the range of $3.79 billion to $3.87 billion based on opening approximately 230 new stores.” At the same time, FIVE claimed that for the second quarter, “Net sales are expected to be in the range of $830 million to $850 million based on opening approximately 60 new stores.” In response to the disclosure, FIVE’s stock price declined $14.07/per share within the span of just one day. On July 16, 2024, FIVE announced the resignation of Joel Anderson from his positions as President and Chief Executive Officer, as well as from his seat on the Company’s Board of Directors. Concurrently, FIVE projected a decrease of 6% to 7% in comparable sales for the fiscal second quarter ending August 3, 2024. Following this news, FIVE’s stock price dropped over 25% on July 17, 2024.

Class Period

3/20/24 - 7/16/24

Deadline

September 30 2024

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23

Days Left

CRWD

CrowdStrike Holdings, Inc.

Deadline

September 30 2024

Class Period

11/29/23 - 7/29/24

Allegations

(1) CrowdStrike had instituted deficient controls in its procedure for updating the Company's main product software, Falcon and was not properly testing updates to Falcon before rolling them out to customers; (2) this inadequate software testing created a substantial risk that an update to Falcon could cause major outages for a significant number of the Company’s customers; and (3) such outages could pose, and in fact ultimately created, substantial reputational harm and legal risk to CrowdStrike. As a result of these materially false and misleading statements and omissions, CrowdStrike stock traded at artificially high prices during the Class Period.

Class Period

11/29/23 - 7/29/24

Deadline

September 30 2024

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24

Days Left

INDV

Indivior PLC

Deadline

October 1 2024

Class Period

2/22/24 - 7/8/24

Allegations

(i) the Company grossly overstated their ability to forecast the negative impact of certain legislation on the financial prospects of Indivior products, which forecasting ability was far less capable and effective than defendants had led investors and analysts to believe; (ii) defendants overstated the financial prospects of the Company's products to treat opioid use disorders and serious mental illnesses, SUBLOCADE, PERSERIS and OPVEE, and thus overstated the Company’s anticipated revenue and other financial metrics; (iii) defendants knew or recklessly disregarded that because of the negative impact of certain legislation on the financial prospects of Indivior’s products, Indivior was unlikely to meet its own previously issued and repeatedly reaffirmed FY 2024 net revenue guidance, including its FY 2024 net revenue guidance for SUBLOCADE, PERSERIS and OPVEE; (iv) defendants knew or recklessly disregarded that Indivior was at a significant risk of, and/or was likely to cease all sales and marketing activities related to PERSERIS; and (v) as a result of the foregoing, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

2/22/24 - 7/8/24

Deadline

October 1 2024

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24

Days Left

DXC

DXC Technology Company

Deadline

October 1 2024

Class Period

5/26/21 - 5/16/24

Allegations

1) the Company had misrepresented its ongoing “transformation journey” and its ability to integrate previously acquired companies and business systems.; 2) DXC had reduced costs such as restructuring and integration by merely deferring them; and 3) despite touting its ongoing success in implementing that integration and repeatedly stressing its commitment to reducing costs, defendants knew or recklessly disregarded that the Company was only able to reduce its restructuring and TSI costs by limiting its integration efforts.

Class Period

5/26/21 - 5/16/24

Deadline

October 1 2024

Learn More

30

Days Left

XPEL

XPEL, Inc.

Deadline

October 7 2024

Class Period

11/8/23 - 5/2/24

Allegations

(i) XPEL’s competitors were siphoning an increasingly large segment of the market; (ii) as a result, the Company’s revenue growth became increasingly dependent upon existing customers and partners; (iii) as a result, the Company’s revenue growth for 2023 and 2024 dwindled; and (iv) 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

11/8/23 - 5/2/24

Deadline

October 7 2024

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30

Days Left

F

Ford Motor Company

Deadline

October 7 2024

Class Period

4/27/22 - 7/24/24

Allegations

(1) the Company had deficiencies in its quality assurance of vehicle models since 2022; (2) as a result, the Company was experiencing higher warranty costs; (3) the Company’s warranty reserves did not accurately reflect the quality issues in vehicles sold since 2022; (4) as a result, the Company’s profitability was reasonably likely to suffer; 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

4/27/22 - 7/24/24

Deadline

October 7 2024

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30

Days Left

LULU

Lululemon Athletica Inc.

Deadline

October 7 2024

Class Period

12/7/23 - 7/24/24

Allegations

(1) the Company was struggling with inventory allocation issues and color palette execution issues; (2) as a result, the Company’s Breezethrough product launch underperformed; (3) as a result of the foregoing, the Company was experiencing stagnating sales in the Americas region; 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

12/7/23 - 7/24/24

Deadline

October 7 2024

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30

Days Left

XPEL

XPEL Technologies Corp.

Deadline

October 7 2024

Class Period

11/28/23 - 5/2/24

Allegations

(i) XPEL’s competitors were siphoning an increasingly large segment of the market; (ii) as a result, the Company’s revenue growth became increasingly dependent upon existing customers and partners; (iii) as a result, the Company’s revenue growth for 2023 and 2024 dwindled; and (iv) 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

11/28/23 - 5/2/24

Deadline

October 7 2024

Learn More

31

Days Left

MRNA

Moderna, Inc.

Deadline

October 8 2024

Class Period

1/18/23 - 6/25/24

Allegations

(i) mRNA-1345, an respiratory syncytial virus vaccine, was less effective than defendants had led investors to believe; (ii) accordingly, mRNA-1345’s clinical and/or commercial prospects were overstated; and (iii) as a result, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

1/18/23 - 6/25/24

Deadline

October 8 2024

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31

Days Left

NNE

NANO Nuclear Energy Inc.

Deadline

October 8 2024

Class Period

5/8/24 - 7/18/24

Allegations

a) NNE’s purported progress toward regulatory approval for the design of its planned micro reactors and fuel fabrication plant was nonexistent; b) NNE’s timelines for commercialization were wildly optimistic, at best, and most likely impossible; c) the foregoing issues were likely to have a material negative impact on the Company’s projected revenues and growth; d) as a result, the Company's financial position and/or prospects were overstated; and e) as a result, defendants’ public statements were materially false and misleading at all relevant times.

Class Period

5/8/24 - 7/18/24

Deadline

October 8 2024

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38

Days Left

CXM

Sprinklr, Inc.

Deadline

October 15 2024

Class Period

3/29/23 - 6/5/24

Allegations

According to the complaint, on December 6, 2023, Sprinklr announced strong 3Q 2024 results and then reduced its estimated growth for the 4Q and full year 2025. The Company blamed it on “subscription renewal pressures” caused by macro headwinds and the “over-rotation” of sales to its Contact Center as a Service (“CCaaS”) market. On an earnings call in September 2023, CEO Ragy Thomas stated that the Company’s investments in AI and the CCaaS opportunity were main contributors to its customer growth. Subsequently, in March several changes were made to the Company’s C-level positions. Analysts commenting on the reduced estimates mention surprise at the timing and shift in the Company’s sales strategy. Following this news, Sprinklr’s stock price fell by $5.59 per share, or approximately 34% to close at $11.11 per share. On June 5, 2024, Sprinklr again announced significantly reduced growth expectations, this time cutting fiscal year 2025 projections another three percent, down to a mere 7% annual growth, again attributing the losses to reduced customer retention in Sprinklr’s core business and macro headwinds. The price of Sprinklr’s common stock declined dramatically. From a closing market price of $10.84 per share on June 5, 2024 Sprinklr’s stock price fell to $9.20 per share on June 6, 2024, a decline of more than 15% in the span of one day.

Class Period

3/29/23 - 6/5/24

Deadline

October 15 2024

Learn More

38

Days Left

STLA

Stellantis N.V.

Deadline

October 15 2024

Class Period

2/15/24 - 7/24/24

Allegations

According to the complaint, Stellantis issued a press release on July 25, 2024, announcing its financial results for the first half of 2024. The Company reported a steep drop in earnings that fell below forecasts, citing weak margins and high inventory at its U.S. operations. In addition, Stellantis’s Chief Executive Officer Carlos Tavares indicated that the Company was ready to dispose of underperforming brands in its portfolio, while Chief Financial Officer Natalie Knight disclosed the need to take “decisive actions to address operational challenges” in North America, including reducing production and prices for the Company’s vehicles. Following this news, Stellantis’s stock price fell over 7% the same day.

Class Period

2/15/24 - 7/24/24

Deadline

October 15 2024

Learn More

38

Days Left

SYM

Symbotic Inc.

Deadline

October 15 2024

Class Period

5/6/24 - 7/29/24

Allegations

According to the complaint, on July 29, 2024, Symbotic announced their 3Q24 financial results and then lowered its revenue guidance for the fourth quarter and full fiscal year 2024. Symbotic attributed their change in guidance to “schedule growth and higher labor costs during the quarter.” Analysts commenting on the stock questioned when management first knew and responded to the issues. Following this news, Symbotic’s stock price opened at $26.36 per share or approximately 25% below the previous day’s close of $35.63 per share.

Class Period

5/6/24 - 7/29/24

Deadline

October 15 2024

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38

Days Left

EXTR

Extreme Networks, Inc.

Deadline

October 15 2024

Class Period

7/27/22 - 1/30/24

Allegations

(a) Extreme was suffering from adverse client demand trends as its clients had ordered more product from Extreme than needed in the wake of the COVID-19 pandemic to avoid supply shortages and because of a lack of alternative sourcing options and thereby had cannibalized their Class Period purchasing needs; (b) Extreme was increasingly offsetting these adverse organic demand trends with the fulfillment of backlog orders in a manner that materially exceeded the proportion represented to investors; (c) as a result of (a)-(b), Extreme was drawing down its backlog at a much faster rate than represented to investors; (d) as a result of (a)-(c), Extreme’s backlog was already decreasing and at a much quicker pace than defendants’ statements to investors that backlog would only “begin to shrink” in 4Q23 and it would be not until “fiscal ‘26 when it really goes back to normal”; (e) as a result of (a)-(d), Extreme’s backlog was not on track to continue increasing to $600 million; and (f) as a result of (a)-(e) above, defendants had materially misrepresented Extreme’s organic demand, revenue growth, and market share gains as the fulfillment of Extreme’s backlog masked a decline in organic demand and attendant revenues.

Class Period

7/27/22 - 1/30/24

Deadline

October 15 2024

Learn More

38

Days Left

PDD

PDD Holdings Inc. f/k/a Pinduoduo Inc.

Deadline

October 15 2024

Class Period

4/30/21 - 6/25/24

Allegations

(1) PDD’s applications contained malware, which was designed to obtain user data without the user’s consent, including reading private text messages; (2) PDD has no meaningful system to prevent goods made by forced labor from being sold on its platform, and has openly sold banned products on its Temu platform; (3) the foregoing subjected the Company to a heightened risk of legal and political scrutiny; 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

4/30/21 - 6/25/24

Deadline

October 15 2024

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38

Days Left

ARDX

Ardelyx, Inc.

Deadline

October 15 2024

Class Period

10/31/23 - 7/1/24

Allegations

(i) defendants had engaged in a scheme to deceive the investing public, including Plaintiff and other Class members; (ii) this scheme artificially inflated and maintained the market price of Ardelyx securities; and (iii) this scheme caused Plaintiff and other members of the Class to purchase or otherwise acquire Ardelyx securities and options at artificially inflated prices.

Class Period

10/31/23 - 7/1/24

Deadline

October 15 2024

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44

Days Left

OFIX

Orthofix Medical Inc.

Deadline

October 21 2024

Class Period

10/11/22 - 9/12/23

Allegations

According to the filed complaint, defendants made false and/or misleading statements and/or failed to disclose that Orthofix’s management team was engaged in “repeated inappropriate and offensive conduct that violated multiple code of conduct requirements,” which was also “inconsistent with the Company’s values and culture.” This revelation was particularly egregious as it followed assurances that Orthofix’s management team consisted of individuals committed to conducting business in accordance with the highest ethical and legal standards, and further, that these individuals believed in and fostered a strong performance-based culture focused on integrity, collaboration, innovation, diversity, and corporate responsibility.

Class Period

10/11/22 - 9/12/23

Deadline

October 21 2024

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44

Days Left

DXCM

DexCom, Inc.

Deadline

October 21 2024

Class Period

1/8/24 - 7/25/24

Allegations

According to the complaint, on July 25, 2024, Dexcom announced its financial results for the second quarter of fiscal 2024 and reduced its revenue guidance for the full fiscal year 2024. The Company attributed its results and lowered guidance on their execution of “several key strategic initiatives” which “did not meet [their] high standards.” Investors and analysts reacted immediately to DexCom’s revelation. The price of DexCom’s common stock declined dramatically. From a closing market price of $107.85 per share on July 25, 2024, DexCom’s stock price fell to $64.00 per share on July 26, 2024, a decline of about 40.66% in the span of just a single day.

Class Period

1/8/24 - 7/25/24

Deadline

October 21 2024

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44

Days Left

SPIR

Spire Global, Inc.

Deadline

October 21 2024

Class Period

3/6/24 - 8/14/24

Allegations

(1) there were embedded leases of identifiable assets and pre-space mission activities for certain Space Services contracts, which allows customers to deploy their own applications and sensors via satellite; (2) Spire Global lacked effective internal controls regarding revenue recognition for these contracts; (3) as a result, the Company overstated revenue for certain Space Services contracts; 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

3/6/24 - 8/14/24

Deadline

October 21 2024

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45

Days Left

STM

STMicroelectronics N.V.

Deadline

October 22 2024

Class Period

1/25/24 - 7/24/24

Allegations

According to the complaint, STMicroelectronics disclosed on July 25, 2024, its U.S. GAAP financial results for the second quarter ending June 29, 2024, and subsequently revised its full-year revenue and margin projections downward for the second time within the current fiscal year. The company now anticipates total revenue for 2024 to fall within the range of $13.2 billion to $13.7 billion, a reduction from the prior forecast of $14 billion to $15 billion. Notably, during the fourth-quarter 2023 earnings call held in January, the company had projected 2024 revenues to range between $15.9 billion and $16.9 billion. For the second quarter, revenue experienced a 25.3% decline year-over-year, amounting to $3.23 billion. Additionally, net sales to Original Equipment Manufacturers (OEMs) and through Distribution channels decreased by 14.9% and 43.7%, respectively, on a year-over-year basis. On this news, the stock dropped over 13% during pre-market trading on July 25, 2024.

Class Period

1/25/24 - 7/24/24

Deadline

October 22 2024

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48

Days Left

MEI

Methode Electronics, Inc.

Deadline

October 25 2024

Class Period

6/23/22 - 3/6/24

Allegations

(a) during the COVID-19 pandemic, the Company had lost highly skilled and experienced employees necessary to successfully complete the Company’s transition from its historic low mix, high volume production model to a high mix, low production model at its Monterrey facility; (b) the Company’s attempts to replace its GM center console production with more diversified, specialized products for a wider array of vehicle manufacturers and original equipment manufacturers, particularly in the EV space, had been plagued by production planning deficiencies, inventory shortages, vendor and supplier problems, and, ultimately, botched execution of the Company’s strategic plans; (c) the Company’s manufacturing systems at its critical Monterrey facility suffered from a variety of logistical defects, such as improper system coding, shipping errors, erroneous delivery times, deficient quality control systems, and failures to timely and efficiently procure necessary raw materials; (d) the Company had fallen substantially behind on the launch of new EV programs out of its Monterrey facility, preventing the Company from timely receiving revenue from new EV program awards; and (e) as a result of (a)-(d) above, the Company was not on track to achieve the 2023 diluted earnings per share guidance or the 3-year 6% organic sales CAGR represented to investors, and such estimates lacked a reasonable factual basis.

Class Period

6/23/22 - 3/6/24

Deadline

October 25 2024

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48

Days Left

DAVA

Endava plc

Deadline

October 25 2024

Class Period

5/23/23 - 2/28/24

Allegations

(1) demand for the Company’s services was declining; (2) the Company’s clients delayed or canceled projects; (3) as a result, the Company’s fiscal 2023 and 2024 revenue and earnings would be adversely affected; 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

5/23/23 - 2/28/24

Deadline

October 25 2024

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51

Days Left

SAGE

Sage Therapeutics, Inc.

Deadline

October 28 2024

Class Period

4/12/21 - 7/23/24

Allegations

(i) Zuranolone, a neuroactive steroid for the treatment of postpartum depression, was less effective in treating Major Depressive Disorder (MDD) than defendants had led investors to believe; (ii) accordingly, the FDA was unlikely to approve the Zuranolone NDA for the treatment of MDD in its present form, and Zuranolone’s clinical results for MDD, as well as its overall regulatory and commercial prospects, were overstated; (iii) SAGE-718 was less effective in treating Mild Cognitive Impairment (MCI) due to Parkinson’s Disease (PD) than defendants had led investors to believe; (iv) accordingly, SAGE-718’s clinical, regulatory, and commercial prospects as a treatment for MCI due to PD were overstated; (v) SAGE-324 was less effective in treating essential tremor than defendants had led investors to believe; (vi) accordingly, SAGE-324’s clinical, regulatory, and commercial prospects as a treatment for essential tremor were overstated; and (vii) as a result of all the foregoing, the Company’s public statements were materially false and misleading at all relevant times.

Class Period

4/12/21 - 7/23/24

Deadline

October 28 2024

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51

Days Left

VERV

Verve Therapeutics, Inc.

Deadline

October 28 2024

Class Period

8/9/22 - 4/1/24

Allegations

(1) defendants did not fully disclose the circumstances under which the Heart-1 Phase 1b clinical trial of VERVE-101, its investigational gene editing medicine, would be halted; (2) defendants overstated the potential benefits of its proprietary lipid nanoparticle delivery system; and (3) 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

8/9/22 - 4/1/24

Deadline

October 28 2024

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51

Days Left

SBUX

Starbucks Corporation

Deadline

October 28 2024

Class Period

11/2/23 - 4/30/24

Allegations

According to the complaint, on April 30, 2024, after market hours, investors began to question the veracity of defendants’ public statements following Starbucks’ press release announcing its second quarter fiscal 2024 earnings and the accompanying same-day earnings call. In pertinent part, defendants announced disappointing Q2 Fiscal 2024 results, stating that store sales declined globally 4%, with traffic falling 7%, and further disclosed a 2% decline in new revenues to $8.6 billion. On the back of these results, Starbucks additionally lowered their guidance for FY 2024, citing global declines in store sales, net revenues, and both GAAP and non- GAAP earnings. The Company attributed its results and lowered guidance on the issues Starbucks was facing in China, with CFO Ruggeri stating, in reference to the Chinese market, “we still see the effects of a slower-than-expected recovery, and we see fierce competition among value players in the market.” Investors and analysts reacted immediately to Starbucks’ revelation. The price of Starbucks’ common stock declined dramatically. From a closing market price of $88.49 per share on April 30, 2024, Starbucks’ stock price fell to $74.44 per share on May 1, 2024, a decline of over 15% in the span of just a single day.

Class Period

11/2/23 - 4/30/24

Deadline

October 28 2024

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51

Days Left

OM

Outset Medical, Inc.

Deadline

October 28 2024

Class Period

8/1/22 - 8/7/24

Allegations

(1) the Tablo products, its primary devices used in dialysis care, were marketed for continuous renal replacement therapy, which is not one of the indications approved by the FDA; (2) as a result, Outset Medical was reasonably likely to submit an additional 510(k) application for the Tablo products; (3) there was a substantial risk that the Company would cease sales of the Tablo products pending FDA approval of additional indications; (4) Outset Medical lacked the sales team and process to execute on the ramp of Tablo sales; (5) as a result of the foregoing, the Company’s revenue growth would be adversely impacted; and (6) 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

8/1/22 - 8/7/24

Deadline

October 28 2024

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52

Days Left

SMCI

Super Micro Computer, Inc.

Deadline

October 29 2024

Class Period

2/2/21 - 8/28/24

Allegations

According to the complaint, on August 27, 2024, Hindenburg Research unveiled a short report on SMCI. The short report detailed several allegations against the Company, including that Hindenburg “found glaring accounting red flags, evidence of undisclosed related party transactions, sanctions and control failures, and customer issues.” Investors and analysts reacted immediately to these revelations. The price of SMCI’s common stock declined dramatically. From a closing market price of $562.51 per share on August 26, 2024, SMCI’s stock price fell to $443.49 per share on August 28, 2024, a decline of about 21.16% in the span of only two days.

Class Period

2/2/21 - 8/28/24

Deadline

October 29 2024

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58

Days Left

GTLB

GitLab Inc.

Deadline

November 4 2024

Class Period

6/6/23 - 3/4/24

Allegations

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 GitLab’s ability to develop AI features that would generate code more efficiently and increase market demand for its DevSecOps platform. On March 4, 2024, GitLab issued a press release reporting a strong Q1 in 2024, followed by an announcement lowering full-year guidance for 2025. In pertinent part, defendants announced that the company needed time to build its pipeline and close deals on new products. In addition, provided first quarter 2025 and full year 2025 guidance with growth rates hovering between 30 and 31% and 27%, respectively. Furthermore, GitLab anticipated a Q1 2025 non-GAAP operating loss of $12-$13 million and an operating non-GAAP revenue of $5-$10 million for the full year of 2025. Investors and analysts reacted immediately to GitLab’s revelation. The price of GitLab’s common stock declined dramatically. From a closing market price of $74.47 per share on March 4, 2024, GitLab’s stock price fell to $58.84 per share on March 5, 2024, a decline of about 21% in the span of just a single day.

Class Period

6/6/23 - 3/4/24

Deadline

November 4 2024

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58

Days Left

ZI

ZoomInfo Technologies Inc.

Deadline

November 4 2024

Class Period

11/10/20 - 8/5/24

Allegations

(a) ZoomInfo’s financial and operational results during the Class Period had been temporarily inflated by the ephemeral effects of the COVID-19 pandemic, which had pulled-forward demand for the Company’s database of digital contact information; (b) material portions of ZoomInfo’s existing customer base were attempting to either substantially reduce their use of the Company’s product or abandon it altogether; (c) that ZoomInfo had used manipulative and coercive auto-renew policies and threats of litigation to force customers into remaining with the Company for an additional contractual term even though such customers did not want to; (d) ZoomInfo’s coercive customer retention tactics had materially damaged the Company’s customer relationships, client franchise, and competitive advantages, and created a hidden demand cliff for costumer contract renewals in future periods; and (e) as a result of (a)–(d), above, ZoomInfo’s reported revenues, operating income, and customer and retention metrics were materially overstated.

Class Period

11/10/20 - 8/5/24

Deadline

November 4 2024

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58

Days Left

WBTN

WEBTOON Entertainment Inc.

Deadline

November 4 2024

Class Period

This lawsuit is on behalf of persons and entities that purchased or otherwise acquired Webtoon common stock pursuant and/or traceable to the registration statement and prospectus issued in connection with the Company’s June 2024 initial public offering.

Allegations

(1) the Company experienced a deceleration in advertising revenue growth; (2) the Company experienced a deceleration in IP adaptations revenue; (3) the Company experienced exposure to weaker foreign currencies which offset revenue growth; (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

This lawsuit is on behalf of persons and entities that purchased or otherwise acquired Webtoon common stock pursuant and/or traceable to the registration statement and prospectus issued in connection with the Company’s June 2024 initial public offering.

Deadline

November 4 2024

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