The Complaint alleges that Defendants failed to disclose to investors: (1) that certain of InnovAge’s facilities failed to provide covered services, provide accessible and adequate services, manage participants’ medical situations, and oversee use of specialists; (2) that, as a result, the Company was reasonably likely to be subject to regulatory scrutiny, including by the Centers for Medicare and Medicaid Services; (3) that, as a result, there as a significant risk that CMS would suspend new enrollments pending an audit of the Company’s services; and (4) that, as a result of the foregoing, Defendants’ positive statements about the Company’s business, operations, and prospects, were materially misleading and/or lacked a reasonable basis.