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(i) DLocal engaged in certain improper conduct and transfers abroad in violation of Argentine laws and/or regulations, including, inter alia, foreign exchange regulations; (ii) accordingly, DLocal’s compliance controls and procedures, including its disclosure controls and procedures and internal controls over financial reporting, were deficient; (iii) all the foregoing subjected the Company to a heightened risk of governmental and/or regulatory scrutiny in Argentina and/or enforcement action by Argentine authorities; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(1) Kenvue faces potential headwinds as a result of confirmed concerns about the efficacy of phenylephrine, which it knew or should have known; (2) Kenvue did not discuss risks relating to the efficacy of phenylephrine (or “PE”) in its IPO, the utility of which had been questioned since at least 2007; (3) while the Company disclosed risks relating to litigation, it did not disclose specific risk relating to potential litigation arising from adverse findings on the efficacy of phenylephrine; and (4) as a result, defendants’ public statements were materially false and misleading at all relevant times and negligently prepared.

The complaint alleges that defendants made false and/or materially misleading statements that: 1) misrepresented the efficacy of AAP’s strategic pricing initiative and the impact of price reductions; 2) omitted and/or concealed the negative impacts of the pricing initiative; 3) provided investors with an overly optimistic perception of AAP’s operations; and 4) created the false impression that inflation and macroeconomic factors had an insubstantial impact on the Company’s margins. On May 31, 2023, AAP held its quarterly earnings call for 2023 first quarter. During that call, President and CEO Thomas R. Greco (“Greco”) conceded, “our financial results in the first quarter were well below expectations.” Because the Company slashed prices on products, Greco stated “we had less price realization than plans, which put substantially higher pressure on our product margin price.” Executive Vice President and Chief Financial Officer, Jeffrey W. Shepherd revealed during the May call that the Company’s strategic pricing program resulted in the Company being “unable to price to cover product costs in the quarter.” The Company consequently revised downward its 2023 guidance to an operating margin of 5% to 5.3% from the previously announced 7.8% to 9.2% margins. Following this news, the Company’s stock price fell by $39.31 per share, from $112.20 per share to $72.89 per share on May 31, 2023.

(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.

(1) the Company experienced challenges with collections from commercial payors; (2) as a result, there was a lower average selling price for the DermTech Melanoma Test; (3) as a result of the foregoing, the Company’s revenue growth would be adversely impacted; and (4) 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) Farfetch was experiencing a significant slowdown in growth in the U.S. and China; (ii) Farfetch also faced onboarding challenges impacting the launch of its Reebok partnership; (iii) Farfetch downplayed challenges it faced with respect to, and/or overstated its ability to manage, its supply chain and inventory; (iv) all the foregoing was having a significant negative impact on Farfetch’s revenue and gross merchandise value growth; (v) accordingly, Farfetch was unlikely to meet market expectations for its Q2 2023 financial results or its own FY 2023 revenue guidance; and (vi) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(a) Figma was growing its market share and was becoming a leader in user experience design; (b) Figma was in direct competition with Adobe on user experience design; (c) Adobe’s product “Express” was not an effective counter to Figma’s growing market share in bringing new customers to Adobe’s paid offerings; (d) Adobe’s other offerings were not succeeding in competing with Figma on user experience design; and (e) Adobe was losing market share to Figma.

(i) DocGo’s executive hiring processes were inadequate to fully review and vet the professional and academic backgrounds of job candidates; (ii) the foregoing increased the likelihood of disruptive executive turnover; (iii) contrary to its representations to investors, DocGo had overstated the efficacy of its mobile health and medical transportation services, the very services contemplated by the relocation contract between the Company and New York City; (iv) all of the foregoing, once revealed, was likely to subject DocGo to significant reputational and/or regulatory scrutiny that would negatively impact the Company’s financial position and/or prospects; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(1) Brainstorm Cell downplayed the severity of the refusal to file letter it received from the U.S. Food and Drug Administration regarding NurOwn ; (2) Brainstorm Cell continued to conceal the risks associated with the submission of the Biologics License Application for NurOwn; 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) contrary to his false public assertions, Barclays' CEO, Jes Staley, had a close relationship with Jeffrey Epstein; (2) Staley was reportedly aware of Jeffrey Epstein’s criminal activities and may have even sexually assaulted a victim who had previously been trafficked by Jeffrey Epstein; (3) Staley’s close, personal relationship with Jeffrey Epstein and potential criminal activity could, if discovered, bring reputational, legal, and financial harm to Barclays; (4) as a result, Barclays response to the British Financial Conduct Authority'("FCA") inquiry regarding Staley’s relationship with Epstein was materially false; (5) Barclays, having become aware of information contradicting its response to the FCA’s inquiry, then failed to update the response so that it would be accurate, or otherwise take any meaningful action; and (6) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all times.

(i) there was a lack of substantial evidence supporting the Company's lead product candidate, ONS-5010, as a treatment for wet age-related macular degeneration; (ii) Outlook and/or its manufacturing partner had deficient chemistry manufacturing and controls and other manufacturing issues for ONS-5010, which remained unresolved at the time the ONS-5010 biologics license application (“BLA”) was resubmitted to the U.S. Food and Drug Administration ("FDA"); (iii) as a result of all the foregoing, the FDA was unlikely to approve the ONS-5010 BLA in its present form; (iv) accordingly, ONS-5010’s regulatory and commercial prospects were overstated; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(1) the Company’s distribution channels in Europe had higher than optimal inventory levels; (2) as a result, the Company was experiencing substantial cancellations and pushouts of existing backlog from its European distributors; (3) as a result, the Company’s backlog and guidance was overstated; 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) as a result of Holley’s extensive focus on its direct-to-consumer (“DTC”) channel, Holley’s critically important relationships with its resellers and distributors, whose business made up the vast majority of Holley’s revenue, were suffering significant damage; (ii) Holley used discounting and other similar efforts to grow its DTC channel, which undermined the pricing discipline Holley historically had with its resellers and distributors and further damaged Holley’s relationship with its resellers and distributors; (iii) as a result of Holley’s strained relationships with its resellers and distributors, those resellers and distributors were decreasing their purchases of Holley products, returning products already purchased at levels far above historical norms, and increasing their purchases of competitors’ products; (iv) Holley’s growing DTC channel could not offset the negative financial impact of the Company's increasingly strained relationships with its resellers and distributors and, as a result, Holley’s critical relationship with resellers and distributors was deteriorating; (v) Holley had failed to successfully integrate and capture synergies from its numerous acquisitions, which left Holley with inefficient operations, excess costs, and inventory management problems; and (vi) Holly benefited from COVID-related stimulus money that temporarily boosted its sales and performance, and despite this unsustainable, temporary boost, defendants misled investors to believe the growth was sustainable and the result of persistent demand and supportive of positive financial guidance.

(1) the Company’s facility in Rochester, New York (the “Rochester Hub”) was experiencing escalating construction costs; (2) these “escalating construction costs” exceeded the expected aggregate cost of the project; (3) as a result, the Company would be forced to temporarily halt construction and reevaluate the construction strategy for the Rochester Hub; and (4) 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.

(1) the diminishment of patent protection for FMC’s flagship products following legal defeats in key markets including India, China, and Brazil had opened the door to increased competition from generics; (2) the Company repeatedly mislead investors about the status of such proceedings and falsely claimed that it did not and would not face generic competition in key markets until 2026 at the earliest; and (3) because of these issues, defendant’s positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

(1) Paycom’s Beti product led to cannibalization of the Company’s services and revenues; (2) Paycom knew but failed to disclose that Beti was leading to cannibalization of the Company’s services and revenues, and failed to warn of cannibalization as a general risk; (3) as a result of cannibalization of revenue, Paycom missed its expected 3Q23 revenue and would have to revise its expected 2023 Revenues; (3) the cannibalization issue resulted in projected 2024 year-over-year revenue growth to between 10% and 12%, well below expectations; 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.

(1) certain of the Company’s insiders had personal financial motives for acquiring GRAIL, Inc.; (2) contrary to Illumina’s attempts to discount Icahn’s criticism, Icahn had accurately concluded that insiders’ interests did not align with the Company’s best interests; 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.

(1) James River lacked effective internal controls regarding the recognition of reinstatement premiums for reinsurance; (2) as a result, the Company overstated its net income; (3) the Company was reasonably likely to restate its financial results; and (4) 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) izokibep, the Company's lead product candidate, was less effective in treating Hidradenitis Suppurativa than defendants had led investors to believe; (ii) accordingly, Acelyrin overstated izokibep’s clinical and/or commercial prospects; (iii) as a result, Acelyrin also overstated the Company’s business prospects post-initial public offering; and (iv) as a result, the Company’s public statements were materially false and misleading at all relevant times.

(1) because of the effect of inflationary pressures on the cost of construction and power, the Company and Utah Associated Municipal Power Systems would be unable to sign up enough subscribers to fulfill the Carbon Free Power Project; (2) Standard Power did not have the financial ability to support its agreement with NuScale; and (3) as a result, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

(1) Syndeo 1.0 and 2.0 devices had issues leading to “frequent treatment interruptions;” (2) as a result, the Company incurred significant costs to develop enhancements; (3) despite the enhancements, providers continued to experience issues with the Syndeo devices; (4) as a result, the Company would no longer market Syndeo 1.0 and 2.0 devices and incur significant inventory write-downs; (5) as a result, the Company’s profitability would be adversely impacted; 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.

(1) Syndeo 1.0 and 2.0 devices had issues leading to “frequent treatment interruptions;” (2) as a result, the Company incurred significant costs to develop enhancements; (3) despite the enhancements, providers continued to experience issues with the Syndeo devices; (4) as a result, the Company would no longer market Syndeo 1.0 and 2.0 devices and incur significant inventory write-downs; (5) as a result, the Company’s profitability would be adversely impacted; 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.

The complaint alleges that on August 2, 2023, the Company held its Q2 2023 earnings call. During that call, President and CEO Aaron P. Jagfeld revealed lackluster quarterly results, including a $1 billion sales decrease year-over-year and that residential sales decreased 44%. When explaining that decline, Jagfeld contradicted his May statements discounting macroeconomic trends. He said, “[the Company] underperformed our expectations as a result of the shift in consumer spending patterns,” thus admitting the importance of inflation on consumer spending. Consequently, Jagfeld advised investors, “[t]his weaker than previously expected demand environment is expected to persist in the second half of the year, also contributing to our lower outlooked for residential product sales.” Generac’s share price dropped swiftly in the day after the earnings call. On August 1, 2023 shares closed to $153.38; by the close on August 3, 2023 shares plummeted to $110.77.

(a) Veradigm had overstated its historical revenues by at least $20 million; (b) Veradigm had artificially inflated its revenue by recording duplicate transactions, among other things, over a more than two-year period; (c) Veradigm had artificially inflated its earnings and margins and materially misrepresented demand for the Company’s products and services during the class period; (d) Veradigm had failed to maintain effective internal controls over its financial reporting; (e) Veradigm had failed to comply with Generally Accepted Accounting Principles (“GAAP”) regarding appropriate revenue recognition practices; and (f) as a result of the foregoing, the Company’s financial projections were materially false and misleading and lacked any reasonable basis.

(a) Dollar General stores were chronically understaffed and suffering from logistical and inventory management problems that left stores with tens of millions of dollars’ worth of outdated and unwanted inventory, mispriced goods, and lost and damaged items; (b) large backlogs of unsellable merchandise had built up at Dollar General’s stores, which inventory had not been timely written down due to understaffing and the Company’s failure to manage its inventory; (c) the allotment of employee hours per store per week imposed by Dollar General management placed employees in virtually impossible situations where assigned tasks, including those necessary for effective store operations, could not be completed within the allotted time; (d) in violation of state laws, including state law violations identified by state regulators in Arizona, Louisiana, Mississippi, Missouri, North Carolina, and Ohio, Dollar General was systematically overcharging customers for items upon checkout; (e) Dollar General’s reported revenue and earnings during the class period were artificially inflated by defendants’ over-pricing scheme; (f) Dollar General’s failure to manage store inventories and accurately price items upon checkout risked the loss of customers, lower sales, adverse regulatory actions, and reputational fallout; (g) Dollar General was not on track to achieve the 4Q22 guidance provided to investors of 6% to 7% same-store sales growth or quarterly diluted EPS of $3.15 to $3.30 and was running more than one hundred million dollars behind the Company’s annual net sales guidance of 11% growth; and (h) as a result of (a)-(g) above, defendants’ statements about Dollar General’s business metrics, operations, and financial prospects were materially false and misleading and/or lacked a reasonable factual basis when made.

(1) the Roblox platform had insufficient content controls and lacked user spending restrictions; (2) these inadequate controls enabled younger Roblox users to play games with inappropriate content and make excessive, unauthorized Robux purchases; (3) a material portion of Roblox’s bookings and revenue growth was due to these excessive, unauthorized Robux purchases; (4) fourth quarter 2021 and 2022 bookings would be negatively impacted by Roblox’s planned rollout of enhanced parental controls; and (5) based on the foregoing, the Company’s bookings and revenue growth was unsustainable throughout the class period.

(1) Fisker had a material weakness in its internal control over financial reporting; (2) Fisker had incorrectly accounted for certain costs; (3) as a result, the Company was likely to delay filing its quarterly report; (4) Fisker’s infrastructure was limiting its ability to deliver its production; 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.

(1) the Company was experiencing higher component costs and supply overruns for first-generation DC charging products; (2) as a result, the Company was likely to incur impairment charges; (3) as a result of the foregoing, the Company’s profitability would be adversely impacted; and (4) 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.