The Complaint alleges that throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operations, and prospects. Specifically, the Complaint alleges Defendants failed to disclose to investors: (1) that RenovaCare engaged in a promotional campaign to issue misleading statements to artificially inflate the Company’s stock price; (2) that, when the OTC Markets inquired, RenovaCare issued a materially false and misleading press release claiming that no director, officer, or controlling shareholder had any involvement in the purported third party’s promotional materials; (3) that, as a result of the foregoing, the Company’s disclosure controls and procedures were defective; and (4) as a result, Defendants’ statements about its business, operations, and prospects were materially false and misleading and/or lacked reasonable basis at all relevant times.