According to the Complaint, Uber purports to be a technology company that primarily facilitates access to rides and meals on demand.

On May 13, 2019, Uber conducted a U.S. initial public offering. The Complaint alleges that the IPO Registration Statement and Prospectus (collectively, the “Offering Documents”) that Uber and the other Defendants used to conduct the IPO were materially false, misleading, and incomplete and omitted to disclose material adverse facts about the Company and its business, including that: (a) The Company was plagued by serious safety problems, which were compounded by patently defective investigative and safety enforcement policies and practices that were shamefully insufficient to adequately prevent, punish, and deter acts of sexual assault and other tortious conduct against Uber customers; (b) The Company was experiencing accelerating losses; and (c) The Company was in violation of and indifferent to existing and pending laws, rules, and regulations in multiple key markets, including in this state (California, where two of its five biggest markets –San Francisco and Los Angeles – are located), thereby exposing Uber to serious regulatory risks and costly liabilities that were either misleadingly understated or completely omitted from the Offering Documents.