The Complaint alleges Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) Piedmont has not, and would not, follow its stated steps or timeline to secure all proper and necessary permits; (2) Piedmont failed to inform relevant people and governmental authorities of its actual plans; (3) Piedmont failed to file proper applications with relevant governmental authorities (including state and local authorities); (4) Piedmont and its lithium business does not have “strong local government support”; and (5) as a result, Defendants’ public statements were materially false and/or misleading at all relevant times.