The filed complaint alleges that Inovio Pharmaceuticals, Inc. made materially false and/or misleading statements and/or failed to disclose that: (i) manufacturing for Inovio’s CELLECTRA device was deficient; (ii) accordingly, Inovio was unlikely to submit it's lead product candidate, INO-3107 BLA to the FDA by the second half of 2024; (iii) Inovio had insufficient information to justify the INO-3107 BLA’s eligibility for FDA accelerated approval or priority review; (iv) accordingly, INO-3107’s overall regulatory and commercial prospects were overstated; and (v) as a result, defendants’ public statements were materially false and misleading at all relevant times.