The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) Li-Cycle's largest customer, Traxys North America LLC, is not actually a customer, but merely a broker providing working capital financial to the Company while Traxys tries to sell Li-Cycle's product to end customers; (2) the Company engaged in highly questionable related party transactions; (3) the Company's mark-to-model accounting is vulnerable to abuse and gave a false impression of growth; (4) a significant portion of the Company's reported revenues were derived from simply marking up receivables on products that had not been sold; (5) the Company's gross margins have likely been negative since inception; (6) the Company will require an additional $1 billion of funding to support its planned growth (which is a figure greater than the Company raised via the merger); and (7) as a result, Defendants' public statements were materially false and/or misleading at all relevant times. When the true details entered the market, the lawsuit claims that investors suffered damages.