We Give Shareholders A Voice.

(1) the Company’s data from the Phase 3 Sierra trial was unlikely to satisfy the FDA’s guidelines for the acceptance and approval of the Company’s targeted radiotherapy, Iomab-B BLA; (2) the additional analyses, including long-term follow-ups that purportedly demonstrated a trend towards improved Overall Survival that the Company provided to the FDA in an attempt to mitigate the Sierra Trial’s poor OS data were unlikely to satisfy the FDA’s guidelines for the acceptance and approval of the Company’s Iomab-B BLA; (3) as a result, the FDA would likely refuse to review the Iomab-B BLA or, if it did consider that BLA, that the application in its current form was unlikely to be approved; and (4), as a result, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

(i) the material weaknesses in SoundHound’s internal controls over financial reporting impaired the Company’s ability to effectively account for corporate acquisitions; (ii) in addition, the Company overstated the extent to which it had remediated, and/or its ability to remediate, the material weaknesses in its internal controls over financial reporting; (iii) as a result of the foregoing material weaknesses, SoundHound’s reported goodwill following the Amelia Acquisition was inflated and would need to be corrected; (iv) further, SoundHound would likely require extra time and expense to effectively account for the SYNQ3 and Amelia Acquisitions; (v) the foregoing increased the risk that the Company would be unable to timely file certain financial reports with the SEC; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

On March 17, 2025, Morpheus Research released a report alleging that the company’s Power Solutions division is built on an overvalued acquisition involving an individual with a history of environmental crimes. Additionally, the report raises concerns about potential overreliance on a single major customer, undisclosed environmental regulatory risks, and questionable financial reporting practices. Following this news, shares of Solaris Energy Infrastructure, Inc. fell over 15% in intraday trading on that day.

(i) Canopy had incurred significant costs producing Claybourne pre-rolled joints in connection with the Claybourne product launch in Canada; (ii) the foregoing costs, in addition to certain indirect costs that Canopy incurred in connection with its Storz & Bickel vaporizer devices, were likely to have a significant negative impact on the Company’s gross margins and overall financial results; (iii) accordingly, defendants had overstated the efficacy of Canopy’s cost reduction measures and the health of its gross margins while downplaying issues with the same; and (iv) as a result, defendants’ public statements were materially false and misleading at all relevant times.

(1) the Company’s backlog conversion cycle had become elongated due to larger, more complex projects; (2) as a result, the Company’s revenue recognition would be delayed; and (3) 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.

According to the complaint, defendants provided investors with material information concerning the failed inspection of Viatris’ Indore, India facility. Defendants’ statements misrepresented the FDA’s issuance of a warning letter and its impact on Viatris' operations. Defendants routinely referred to the impact of the warning letter as a mere “minor headwind” for the Company. On February 27, 2025, Viatris announced its financial results for the fourth quarter and full fiscal year 2024 and provided disappointing fiscal 2025 guidance. The Company attributed below-expectation guidance on “the expected financial impact from Indore facility warning letter and import alert.” Following this news, the price of Viatris’ common stock declined dramatically. From a closing market price of $11.24 per share on February 26, 2025, Viatris’ stock price fell to $9.53 per share on February 27, 2025, a decline of about 15.21% in the span of just a single day.

According to the complaint, Cerevel’s October 16, 2023 secondary stock offering (the “October Offering” or “Offering”) documents and other public statements omitted material facts regarding AbbVie’s interest in acquiring Cerevel at a price well in excess of the $22.81 per share Offering price, artificially deflating Cerevel’s stock price until the merger was announced. Moreover, Cerevel’s controlling shareholder, Bain Capital Investors, LLC (“Bain”), acquired Cerevel shares from the October Offering at an artificially depressed price while allegedly in possession of material nonpublic information regarding AbbVie’s interest. On December 6, 2023, Cerevel publicly announced that AbbVie agreed to acquire Cerevel for $45 per share. The merger allowed Bain to receive a windfall of more than $120 million on the shares it acquired at the artificially depressed Offering price. In addition, Cerevel’s January 18, 2024 Proxy statement misled investors regarding the true nature and timing of AbbVie’s interest in Cerevel.

(1) competition impacted the demand for and utilization of its primary product, the 3D bunion correction system, the “Lapiplasty”; (2) as a result, Treace Medical’s revenue declined and the Company needed to accelerate its plans to offer a product that was an alternative to osteotomy (a surgical procedure that involves cutting and realigning a bone to improve its position or function); and (3) defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

(i) BigBear maintained deficient accounting review policies related to the reporting and disclosure of certain non-routine, unusual, or complex transactions; (ii) as a result, the Company incorrectly determined that the conversion option within the 2026 Convertible Notes qualified for the derivative scope exception under ASC 815-40 and failed to bifurcate the conversion option as required by ASC 815-15; (iii) accordingly, BigBear had improperly accounted for the 2026 Convertible Notes; (iv) the foregoing error caused BigBear to misstate various items in several of the Company’s previously issued financial statements; (v) as a result, these financial statements were inaccurate and would likely need to be restated; (vi) BigBear would require extra time and expense to correct the inaccurate financial statements, thereby increasing the risk that the Company would be unable to timely file certain financial reports with the SEC; and (vii) as a result, the Company’s public statements were materially false and misleading at all relevant times.

According to the filed complaint, defendants made false statements and/or concealed that they did not properly warn investors of the risks concerning Ibotta’s contract with The Kroger Co. (“Kroger”). Kroger’s contract was at-will, and Ibotta failed to warn investors that a large client could cancel their contract with Ibotta without warning. Despite providing a detailed explanation of the terms of Ibotta’s contract with Walmart, there was not a single warning of the at-will nature of Kroger’s contract. Rather than disclosing the very real risk of a major client walking away at any time, Ibotta provided boilerplate warnings concerning the importance of maintaining ongoing relationships with their clients.

(1) Zenas BioPharma materially overstated the amount of time that it would be able to fund its operations using existing cash and expected net proceeds from the IPO; and (2) as a result, defendants’ public statements were materially false and misleading at all relevant times and negligently prepared.

(i) Net Power was unlikely to complete its first utility-scale plant, Project Permian, on schedule and the project was likely to be significantly more expensive than defendants had represented, because of, inter alia, supply chain issues and numerous site- and region-specific challenges; (ii) accordingly, defendants’ projections regarding the time and capital needed to complete Project Permian were unrealistic; (iii) the increased time and capital needed to complete Project Permian were likely to have a significant negative impact on the Company’s business and financial results; and (iv) as a result, defendants’ public statements were materially false and misleading at all relevant times.

According to the complaint, defendants provided investors with material information concerning Napco’s overall expected growth and strength in the Company’s hardware division. Defendants’ statements included, among other things, confidence in Napco’s ability to achieve its fiscal 2026 growth projections on back of its ability to both appropriately forecast and execute upon the alleged demand for its hardware products. On February 3, 2025, Napco announced its financial results for the second quarter of fiscal 2025, revealing a significant reduction in hardware sales for the quarter. The Company attributed the decline “primarily … to reduced sales from 2 of the company’s larger distributors.” As a result of the setback in sales, defendants additionally pulled back their long-term 45% EBITDA margin target, as they “don’t know” if the target can be achieved by the end of fiscal 2026. Following this news, Napco’s common stock declined dramatically. From a closing market price of $36.70 per share on January 31, 2024, Napco’s stock price fell to $26.93 per share on February 3, 2025, a decline of about 26.62% in the span of just a single day.

(i) Avis Budget crafted and implemented a plan to significantly accelerate its fleet rotation in the fourth quarter of 2024; (ii) the foregoing acceleration shortened the useful life of the majority of the Company’s vehicles in the Americas segment, thereby reducing their recoverable value; (iii) as a result, Avis Budget would be forced to recognize billions of dollars in impairment charges and incur substantial losses; (iv) all the foregoing was likely to, and did, have a significant negative impact on the Company’s financial results; (v) accordingly, Avis Budget’s financial and/or business prospects were overstated; and (vi) as a result, defendants’ public statements were materially false and misleading at all relevant times.

According to the filed complaint, defendants made false statements and/or concealed that they: (1) misrepresented the capabilities of the Company’s risk-based pricing models; (2) issued materially misleading statements regarding the Company’s profit share revenue; (3) failed to disclose the Company’s 2021 and 2022 vintage loans had become worth significantly less than their corresponding outstanding loan balances; and (4) misrepresented the underperformance of the Company’s 2023 and 2024 vintage loans. 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.

(i) Civitas was highly likely to significantly reduce its oil production in 2025 as a result of, inter alia, declines following the production peak at the DJ Basin in the fourth quarter of 2024 and a low TIL count at the end of 2024; (ii) increasing its oil production would require the Company to acquire additional acreage and development locations, thereby incurring significant debt and causing the Company to sell corporate assets to offset its acquisition costs; (iii) the Company’s financial condition would require it to implement disruptive cost reduction measures including a significant workforce reduction; (iv) accordingly, Civitas’s business and/or financial prospects, as well as its operational capabilities, were overstated; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(a) despite claiming strong visibility into customer demand and attributing headwinds to temporary COVID-related product destocking, West was in fact experiencing significant and ongoing destocking across its high-margin HVP portfolio; (b) West’s SmartDose device, which was purportedly positioned as a high-margin growth product, was highly dilutive to the Company’s profit margins due to operational inefficiencies; (c) these margin pressures created the risk of costly restructuring activities, including the Company’s exit from continuous glucose monitoring contracts with longstanding customers; and (d) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially false and/or misleading or lacked a reasonable basis.

(1) UnitedHealth had, for years, engaged in a corporate strategy of denying health coverage in order to boost its profits, and ultimately, its share price; (2) this anti-consumer strategy resulted in regulatory scrutiny against UnitedHealth, which ultimately resulted in the murder of Brian Thompson; (3) animus towards UnitedHealth was such that, subsequent to the murder of Mr. Thompson, many Americans openly celebrated his demise, expressed admiration for his accused killer, and/or otherwise demanded that UnitedHealth change its strategy even if they condemned Mr. Thompson’s killing; (4) the foregoing regulatory and public outrage caused UnitedHealth to change its corporate practices; (5) notwithstanding the foregoing, UnitedHealth recklessly stuck with the guidance it issued the day before Thompson’s murder, which was unrealistic considering the Company’s changing corporate strategies; and (6) as a result, defendants’ public statements were materially false and/or misleading at all relevant times.

(1) a large commercial partner would not renew a large contract on the same terms; (2) as a result, Digimarc would renegotiate the large commercial contract; (3) based on this renegotiation, the Company’s subscription revenue and annual recurring revenue would be adversely affected; (4) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading or lacked a reasonable basis.

(i) Bitfarms maintained deficient internal controls over financial reporting; (ii) as a result, the Company incorrectly categorized proceeds derived from the sale of digital assets as a cash flow from operating activities rather than as a cash flow from investing activities; (iii) in addition, the Company overstated the extent to which it had remediated, and/or its ability to remediate, the material weakness in its internal controls over financial reporting related to its classification of the 2021 Warrants; (iv) the foregoing errors caused Bitfarms to misstate various items in several of the Company’s previously issued financial statements; (v) as a result, these financial statements were inaccurate and would likely need to be restated; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

According to the complaint, throughout the class period, defendants failed to disclose to investors that Compass lacked effective internal controls over its financial reporting; that Compass failed to disclose critical information regarding Lugano Holding, Inc. (“Lugano”) which kept undisclosed financing arrangements and exhibited irregularities in its sales, cost of sales, inventory and accounts receivable; and that, as a result of the foregoing, defendants’ positive statements about the Company’s financial reporting were materially misleading. The truth emerged on May 7, 2025, after the market closed, the Company announced that its financial statements for fiscal 2024 could no longer be relied upon due to an ongoing internal investigation into its subsidiary, Lugano. Specifically, Compass reported that its Audit Committee launched an investigation over “concerns about how Lugano was potentially financing inventory.” The Company also announced that it intends to delay the filing of its first quarter 2025 Form 10-Q. Further, effective May 7, 2025, Lugano’s founder and CEO, Moti Ferder, resigned from Lugano and will not receive any severance compensation. Following this news, the price of Compass’ common stock declined dramatically. From a closing market price of $17.25 per share on May 7, 2025 to $6.55 per share on May 8, 2025.

(a) Rocket’s gain on sale margins were contracting at the highest rate in two years as a result of increased competition among mortgage lenders, an unfavorable shift toward the lower margin Partner Network operating segment and compression in the price spread between the primary and secondary mortgage markets; (b) Rocket was engaged in a price war and battle for market share with its primary competitors in the wholesale market, which was further compressing margins in Rocket’s Partner Network operating segment; (c) the adverse trends identified above were accelerating and, as a result, Rocket’s gain on sale margins were on track to plummet at least 140 basis points in the first six months of 2021; (d) as a result of the above, the favorable market conditions that had preceded the Class Period and allowed Rocket to achieve historically high gain on sale margins had vanished as the Company’s gain on sale margins had returned to levels not seen since the first quarter of 2019; (e) rather than remaining elevated due to surging demand, Rocket’s Company-wide gain-on-sale margins had fallen materially below recent historical averages; and (f) 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.

According to the complaint, throughout the class period, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of Iovance’s growth potential; notably, that it was not equipped to generate and drive demand or was otherwise ill equipped to capitalize upon the purported existing demand for its treatments through its network of approved treatment centers. On July 25, 2024, Iovance announced its financial results for the second quarter of fiscal 2024 and reduced its revenue guidance for the full fiscal year 2024. The Company attributed its results and lowered guidance on 1) “the iCTC completed annual scheduled maintenance in December” and “capacity was reduced by more than half for about 1 month,” 2) “[l]ower Proleukin sales” than the company expected, and 3) “the variable pace at which ATCs began treatment patients.” Following this news, the price of Iovance’s common stock declined dramatically. From a closing market price of $3.17 per share on May 8, 2025, Iovance’s stock price fell to $1.75 per share on May 9, 2025, a decline of about 44.795% in the span of just a single day.

(i) the anticipated profitability of the Company’s bitcoin-focused investment strategy and treasury operations was overstated; (ii) the various risks associated with bitcoin’s volatility and the magnitude of losses Strategy could recognize on the value of its digital assets following its adoption of ASU 2023-08 were understated; and (iii) as a result, defendants’ public statements were materially false and misleading at all relevant times.

(1) demand for Krispy Kreme products declined materially at McDonald’s locations after the initial marketing launch; (2) demand at McDonald’s locations was a driver of declining average sales per door per week; (3) the partnership with McDonald’s was not profitable; (4) the foregoing posed a substantial risk to maintaining the partnership with McDonald’s; (5) as a result, the Company would pause expansion into new McDonald’s locations; and (6) 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.

According to the complaint, defendants provided overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of Organon’s priorities, particularly, related to capital allocation through quarterly dividends. Notably, defendants concealed the high priority of Organon’s debt reduction strategy following the Company’s acquisition of Dermavant, resulting in a 70% decrease for the regular quarterly dividend. Following this news, the price of Organon’s common stock declined dramatically. From a closing market price of $12.93 per share on April 30, 2025, Organon’s stock price fell to $9.45 per share on May 1, 2025, a decline of more than 27% in the span of just a single day.