The filed complaint alleges that Nikola Corporation made materially false and/or misleading statements and/or failed to disclose that: (i) the Company maintained deficient safety and structural controls related to its manufacturing of battery components; (ii) the foregoing deficiencies rendered Nikola’s vehicles unsafe to operate and thus unusable, thereby raising the likelihood of a product recall; and (iii) as a result, the Company’s public statements were materially false and misleading at all relevant times.