The Complaint alleges that the Registration Statement contained false and/or misleading statements and/or failed to disclose that: (1) Defendants had overstated BlueCity’s business and financial prospects; (2) BlueCity was ill-equipped to absorb the costs of becoming a publicly traded company, including IPO- and growth-related costs; (3) as a result of all the foregoing, Defendants had misrepresented BlueCity’s capability for sustainable growth; and (4) as a result, the Offering Documents were materially false or misleading and failed to state information required to be stated therein.