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(i) the ADX-2191 new drug application ("NDA") did not include adequate and well-controlled investigations and thus failed to show substantial evidence of ADX-2191’s effectiveness; (ii) as a result, the FDA was unlikely to approve the ADX-2191 NDA in its current form; (iii) accordingly, the Company had overstated ADX-2191’s clinical and/or commercial prospects; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(1) the GTF engines had been affected from at least 2015-2020 by a quality control issue; (2) this quality control issue would require RTX to recall and reinspect many of its GTF airplanes, affecting customers and harming its business; and (3) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(1) Bridgelink Commodities, LLC (“Bridgelink”) is connected to a group whose assets were seized by a creditor and sold in an auction; (2) as such, Bridgelink’s commitment and ability to purchase Eos products was not as secure as Eos had led investors to believe; (3) as such, Eos’s backlog was overstated; (4) such overstatement negatively impacts Eos’s ability to secure a loan from the Department of Energy; and (5) 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.

(a) Hayward and its management had engaged in a channel-stuffing scheme designed to artificially boost Hayward’s short-term sales and earnings; (b) Hayward had flooded its channel partners with inventory that they did not want or need at a level that far outpaced then-existing consumer demand; (c) Hayward’s channel partners were suffering from an inventory glut as a result of the channel-stuffing scheme that would require a massive destocking in the second half of 2022; (d) Hayward’s channel-stuffing scheme had cannibalized future sales, materially impairing the Company’s ability to sell to its customers; (e) the demand for pool equipment had slowed down, which, combined with flooding channel partners with more inventory, led to an inventory glut and the need for these channel partners to reduce inventory levels; and (f) as a result of (a)-(e) above, Hayward’s projected 2022 financial results were not achievable and lacked a reasonable basis in fact.

(1) the design of SYFOVRE’s clinical trials was insufficient to identify incidents of retinal vasculitis in patients receiving SYFOVRE injections; (2) as a result, the commercial adoption of SYFOVRE was subject to significant, unknown risk factors; and (3) therefore, defendants’ statements about the Company’s business, operations, and prospects lacked a reasonable basis.

(1) Verizon owns cables around the country that are highly toxic due to being wrapped in lead, and which harm Company employees and non-employees alike; (2) it faces potentially significant litigation risk, regulatory risk, and reputational harm as a result of its ownership of these lead cables and the health risks stemming from their presence around the United States; (3) it was warned about the damage and risks presented by these cables but did not disclose that they posed a threat to employee safety, to everyday people, and communities around the country; and (4) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(i) the Company affirmatively misrepresented that its capital resources “will be adequate to meet our liquidity needs for at least the next 12 months”; (ii) omitted that there was substantial doubt about the Company’s ability to continue as a going concern; (iii) downplayed the nature and extent of the Company’s then-existing liquidity problems; (iv) omitted that the Company’s existing credit facilities were insufficient to satisfy its operational needs and that it was unable to obtain additional loans in the normal course of business; and (v) omitted that there was a material weakness in its internal control over financial reporting.

(1) the GTF engines had been affected from at least 2015-2020 by a quality control issue; (2) this quality control issue would require RTX to recall and reinspect many of its GTF airplanes, affecting customers and harming its business; and (3) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(1) Live Nation engaged in anticompetitive conduct, including charging high fees and extended contracts with talent, and retaliated against venues; (2) as a result, Live Nation was reasonably likely to incur regulatory scrutiny and face fines, penalties, and reputational harm; 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.

(i) Key downplayed concerns with its liquidity while overstating the effectiveness of its long-term liquidity strategy; (ii) Key overstated its projected net interest income (“NII”) for the second quarter and full year of 2023, as well as related positive NII drivers, while downplaying negative NII drivers; (iii) as a result, Key was likely to negatively revise its previously issued NII guidance; (iv) all the foregoing, once revealed, was likely to negatively impact Key’s business, financial results, and reputation; and (v) as a result, defendants’ public statements were materially false and/or misleading at all relevant times.

(i) Applied Digital had overstated the profitability of its datacenter hosting business and its ability to successfully transition into a low-cost AI Cloud services provider; (ii) Applied Digital’s Board of Directors was not independent within the meaning of NASDAQ listing rules; (iii) accordingly, Applied Digital had overstated the efficacy of its business model and failed to maintain proper corporate governance standards; (iv) the foregoing, once revealed, was likely to subject the Company to significant financial and/or reputational harm; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(i) Shift4 had inadequate disclosure controls and procedures and internal control over financial reporting; (ii) as a result, Shift4 failed to properly account for customer acquisition costs, thereby artificially inflating its net cash provided by operating activities; (iii) accordingly, Shift4 would likely be forced to restate one or more of its previously issued financial statements; (iv) Shift4 employed accounting maneuvers in connection with, among other things, its mass strategic buyout program and sponsor bank merchant settlement account, that were designed to present an inaccurate picture of, inter alia, the Company’s performance, its underlying business quality, and its earnings power; (v) all the foregoing, once revealed, was likely to negatively impact Shift4’s reputation and business; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(1) Comerica failed to provide meaningful oversight over the vendors to whom it contracted out day-to-day operations of the Direct Express program, a system through which it is contracted to provide federal benefits on debit cards to millions of Americans without bank accounts; (2) as a result of violations in the day-to-day operations of Direct Express, including handling fraud disputes and allowing sensitive data to be handled out of a vendor’s office in Pakistan, Comerica was not in compliance with the Federal Contract, and knew it was not in compliance; (3) Comerica knew and failed to disclose that it was in potential violation of Regulation E due to inadequate fraud prevention in the Direct Express program and responses to instances of fraud, and; (4) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

According to the complaint, defendants provided investors with material information concerning Masimo’s revenue and sales for the second quarter of fiscal 2023 and expected revenue for the full-year 2023. Defendants’ statements included, among other things, Masimo’s ability to deliver clinically proven new products to the healthcare markets thereby supporting defendants’ decision to forecast revenue of $550 million to $565 million for the quarter and increase its earnings-per-share estimates to between $3.59 per share and $3.69 per share. Defendants’ statements in this regard prompted an immediate and dramatic increase in the price of Masimo’s common stock. From a closing price of $167.31 per share on February 28, 2023 at the start of the Class Period, Masimo’s stock price climbed to $184.97 per share the following day on March 1, 2023 on unusually high volume. Defendants provided these overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts. On July 17, 2023 Masimo issued a press release announcing its second quarter 2023 earnings. Defendants announced lower than expected revenue for the second quarter of fiscal 2023 and preliminarily decreased full-year revenue estimates for both healthcare and non-healthcare segments. On this news, the price of Masimo’s common stock declined dramatically. From a closing market price of $147.16 per share on July 17, 2023, Masimo’s stock price fell to $117.73 per share on July 18, 2023, a decline of nearly 20% in the span of just a single day.

(i) Hawaiian Electric’s wildfire prevention and safety protocols and procedures were inadequate to meet the challenges for which they were ostensibly designed; (ii) accordingly, despite knowing the degree of risk that wildfires posed to Maui, the Company’s inadequate safety protocols and procedures placed Maui at a heightened risk of devastating wildfires; and (iii) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(1) Origin would not be able to meet its previously announced timeline for the construction of the Origin 2 plant; (2) demand for paraxylene (“PX”) had dropped such that it would not be the production focus of Origin 2; (3) Origin could not construct Origin 2 at its previously disclosed cost; (4) Origin could not construct Origin 2 at the scale it had previously identified; and (5) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and lacked a reasonable basis.

The complaint alleges that on December 7, 2021, AeroVironment announced second quarter results below market estimates and reduced revenue guidance for the remainder of the fiscal year from a range of $560 million to $580 million to a range of $440 million to $460 million. AeroVironment also lowered its EBITDA guidance from $105 million to $110 million to $59 million to $65 million. On this news, AeroVironment’s stock declined the following day by nearly 30% to close at $57.98/share causing significant losses to shareholders at the time.

(1) NAPCO failed to address any material weaknesses with internal controls regarding cost of goods sold ("COGS") and inventory; (2) NAPCO downplayed the severity of material weaknesses regarding their internal controls; (3) NAPCO’s unaudited financial statements from September 30, 2022 to the present included “certain errors” such as overstating inventory and understanding net COGS, resulting in overstated gross profit, operating income and net income for each period; (4) as a result, NAPCO would need to restate its previously filed unaudited financial statements for certain periods; and (5) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

(i) DFS maintained deficient risk management and compliance procedures; (ii) as a result of the foregoing deficiencies, the Company had, inter alia, failed to comply with applicable student loan servicing standards, misclassified certain credit card accounts, overcharged customers, and failed to stem its ballooning credit card delinquency rate; (iii) the foregoing issues, when they became known, would subject DFS to significant financial exposure, regulatory scrutiny, and reputational harm; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.

According to the complaint, the defendants made false statements and/or concealed that: (a) MaxLinear, Inc. (“MaxLinear”) had decided it would not consummate a business combination with Silicon Motion (the “Merger”) because the economic circumstances surrounding the Merger had materially changed, including a material downturn in the semiconductor industry and rising interest rates; (b) MaxLinear had determined to unilaterally terminate the Merger in the event the Merger was approved by China’s State Administration for Market Regulation (“SAMR”); (c) MaxLinear intended to argue that certain conditions in Article 6 of the Merger Agreement had not been satisfied as required by May 5, 2023 (i.e., before the Class Period) as a basis to terminate the Merger; and (d) as a result of (a)-(c) above, defendants had materially misrepresented the viability of the Merger, the purported benefits of the Merger, and the likelihood that the Merger would be consummated.

(a) UiPath had enacted a widespread discounting program prior to the IPO, which had the effect of temporarily boosting the Company’s revenue and annualized renewal run-rate ("ARR") metrics, cannibalizing its future sales, eroding the Company’s margins, and increasing the risk of client churn; (b) UiPath’s actual total addressable market was not as large as portrayed by defendants, because many companies included in the market survey did not need the type of high-cost, high-functionality automation products offered by the Company; (c) UiPath was losing customers to Microsoft, ServiceNow, SAP, Salesforce, IBM, and other established enterprise software vendors that were building automation into their platforms; (d) UiPath was losing customers due to the increased availability of lowcode automation software offered by vendors, such as Microsoft’s Power Automate software, which were capable of addressing the majority of customer use cases at a fraction of the price of UiPath’s products and services; (e) UiPath was suffering from a loss of channel sales due to strained relationships with the Company’s partners as a result of increased competition between UiPath and these partners; and (f) as a result of (a)-(e) above, defendants’ statements during the Class Period regarding the Company’s business, operations, and key financial metrics such as revenues and ARR were materially false and misleading.

(1) the Company’s growth was caused by customers over purchasing products to stockpile in case of a chemical shortage; (2) such sales inflated revenues and earnings and were not indicative of durable and sustainable demand or financial growth; (3) the Company took advantage of chemical shortages by urging customers to stock up on the products because Leslie’s could not “guarantee availability” of chemicals in the future; and (4) any slowdown in sales was not a normalization of past seasonality, but was due to the prior excess stockpiling. As a result, defendants’ positive statements about the Company’s financial guidance, business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.

According to the complaint, defendants provided investors with material information concerning Tandem’s projected revenue and sales for the year ending 2022. On August 2, 2022, Tandem estimated annual sales “to be in the range of $835 million to $845 million, which represents an annual growth of 19 percent to 20 percent compared to 2021.” Defendants provided these statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts. The truth emerged on November 2, 2022 when Tandem, in an investment call and Form 8-K filing, revised its 2022 forecast downward to $800 to $805 million. Reasons stated for the scale back included increased competition in the diabetes care sector, complications due to the COVID pandemic, and macroeconomic factors such as inflation. Investors and analysts reacted immediately to Tandem’s revised guidance. The price of Tandem’s common stock declined dramatically. On November 2, 2022, Tandem closed at $51.34; however, on November 3, 2022 Tandem closed at $35.72 – a one-day decline of 30.4%.

(1) defendants lacked the skills and experience to assess complicated tax matters and therefore did not design or maintain effective controls over the Company’s accounting for income taxes; and (2) as a result of the foregoing, defendants’ financial statements during the Class Period were inaccurate and materially misleading.

(i) PacWest had understated the impact of interest rate hikes on Pacific Western Bank (“PWB”), a smaller bank with excessive concentration in specific industries; (ii) accordingly, the Company had overstated the stability and/or sustainability of its deposit base; (iii) as a result, PacWest was exceptionally vulnerable to excessive deposit flows and/or a liquidity crisis; and (iv) as a result, defendants’ public statements were materially false and/or misleading at all relevant times.

According to the complaint, defendants made false statements and/or concealed that Integra had failed to take sufficient measures to remediate the violations identified by the FDA in the November 2, 2018 Notice of Inspectional Observations on Form 483 (the “2018 Form 483”), the March 6, 2019 FDA issued warning letter (the “2019 Warning Letter”), and the November 12, 2021 FDA issued Form 483 (the “2021 Form 483”). As a result of those deficiencies, since March 2018, all products manufactured in the Boston Facility had the potential for higher-than-permitted levels of endotoxin and would need to be recalled. Moreover, the Company was not making progress towards obtaining its premarket approval (“PMA”) indication for SurgiMend, in part, because the manufacturing site that would produce the PMA product, the Boston Facility, was in continued violation of the FDA standards that Integra failed to rectify years after the initial notice of the violations and as a result the facility had to be shutdown to correct those ongoing deficiencies.

According to the complaint, defendants made materially false and misleading statements and failed to disclose material information about the financial condition of the Company including its EBITDA and net loss forecasts, liquidity position, capital allocations, operation costs, productivity and the impact of these metrics on the Company’s ability to continue paying dividends in 2023.

(i) Lumen owned and/or still owns thousands of miles of cables wrapped in lead, a known neurotoxin, within the U.S.; (ii) the foregoing has harmed and posed the risk of further harming the environment, exposed Company employees, and the general public, thereby posing a significant public health risk and environmental pollution risk; (iii) Lumen was on notice about the damage and risks presented by these lead-covered cables but did not disclose them as a potential threat to everyday people and communities, as well as failed to provide adequate lead training to employees; (iv) all the foregoing subjected the Company to a heightened risk of governmental and regulatory oversight and enforcement action, as well as legal and reputational harm; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(i) strong, rapid growth in revenues attributed to customer usage of CS Disco's cloud-based electronic discovery platform was, in fact, attributable to just a handful of large customers; (ii) there were significant headwinds to growing CS Disco's revenues; (iii) CS Disco lacked advance visibility into changes in demand from individual customers over time; and (iv) as a result of the foregoing, defendants' positive statements and purported risk disclosures about the Company's business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

(i) the Company relied on heavily edited videos of earlier flights to exaggerate the amount of flight testing it had actually performed and the sophistication of its eVTOL aircraft; (ii) the Company had misrepresented the nature and profitability of its business partnerships, (iii) the Company was unlikely to secure FAA certification in the timeframe it had represented to investors, thereby delaying the start of mass production of its aircraft for commercial sales; (iv) accordingly, the Company had overstated its financial position and/or prospects; (v) all of the foregoing, once revealed, was likely to subject the Company to significant financial and/or reputational harm; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.