The filed complaint alleges that Red Cat Holdings, Inc. made materially false and/or misleading statements and/or failed to disclose that: (i) the Salt Lake City Facility’s production capacity, and defendants’ progress in developing the same, was overstated; (ii) the overall value of the U.S. Army’s Short Range Reconnaissance Program of Record Tranche 2 contract was overstated; and (iii) as a result, defendants’ public statements were materially false and misleading at all relevant times.