The filed complaint alleges that Li-Cycle Holdings Corp. made materially false and/or misleading statements and/or failed to disclose that: (1) the Company’s facility in Rochester, New York (the “Rochester Hub”) was experiencing escalating construction costs; (2) these “escalating construction costs” exceeded the expected aggregate cost of the project; (3) as a result, the Company would be forced to temporarily halt construction and reevaluate the construction strategy for the Rochester Hub; 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.