The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operations, and prospects. Specifically, Defendants failed to disclose that: (i) HyreCar had materially understated its insurance reserves; (ii) HyreCar had systematically failed to pay valid insurance claims incurred prior to the Class Period; (iii) HyreCar had incurred significant expenses transitioning to its new third-party insurance claims administrator and processing claims incurred from prior periods; (iv) HyreCar had failed to appropriately price risk in its insurance products and was experiencing elevated claims incidence as a result; (v) HyreCar had been forced to dramatically reform its claims underwriting, policies and procedures in response to unacceptably high claims severity and customer complaints; and (vi) as a result of the foregoing, HyreCar's operations and prospects were misrepresented because the Company was not on track to meet the financial estimates provided to investors during the Class Period, and such estimates lacked a reasonable basis in fact, including HyreCar's purported gross margin, EBITDA and net loss trajectories.