The filed complaint alleges that Ostin Technology Group Co., Ltd. made materially false and/or misleading statements and/or failed to disclose that: (a) defendants and other select investors were conspiring on the receipt and subsequent sale of OST shares obtained through the registered direct offering and the warrant exchange agreement during a campaign to artificially inflate OST's stock price; and (b) defendants were conspiring to assist co-conspirators with setting up brokerage accounts to eventually dump OST shares obtained as part of the registered direct offering and warrant exchange agreement.