The filed complaint alleges that Kyverna Therapeutics, Inc. made materially false and/or misleading statements and/or failed to disclose that: (i) the strategy to best accomplish the IPO; (ii) the terms of the IPO, including the price at which Kyverna’s common stock would be sold; (iii) the language to be used in the Offering Documents; (iv) what disclosures about Kyverna would be made in the Offering Documents; and (v) what responses would be made to the SEC in connection with its review of the Offering Documents. As a result of those constant contacts and communications between the underwriter defendants’ representatives and Kyverna’s management, directors, and lawyers, at a minimum, the underwriterd defendants should have known of Kyverna’s undisclosed then-existing problems and plans, and the Offering Document’s materially inaccurate, misleading, and incomplete statements and omissions, as detailed herein.