According to the filed complaint, defendants made false statements and/or concealed that they did not properly warn investors of the risks concerning Ibotta’s contract with The Kroger Co. (“Kroger”). Kroger’s contract was at-will, and Ibotta failed to warn investors that a large client could cancel their contract with Ibotta without warning. Despite providing a detailed explanation of the terms of Ibotta’s contract with Walmart, there was not a single warning of the at-will nature of Kroger’s contract. Rather than disclosing the very real risk of a major client walking away at any time, Ibotta provided boilerplate warnings concerning the importance of maintaining ongoing relationships with their clients.