The filed complaint alleges that Brainstorm Cell Therapeutics Inc. made materially false and/or misleading statements and/or failed to disclose that: (1) Brainstorm Cell downplayed the severity of the refusal to file letter it received from the U.S. Food and Drug Administration regarding NurOwn ; (2) Brainstorm Cell continued to conceal the risks associated with the submission of the Biologics License Application for NurOwn; 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.