The Complaint alleges that the Registration Statement was materially false and misleading and omitted to state: (1) that contracted suppliers, including MinerVa, were reasonably likely to miss anticipated delivery quantities and deadlines; (2) that, due to strong demand and pre-sold supply of mining equipment in the industry, Stronghold would experience difficulties obtaining miners outside of confirmed purchase orders; (3) that, as a result of the foregoing, there was a significant risk that Stronghold could not expand its mining capacity as expected; (4) that, as a result, Stronghold would likely experience significant losses; and (5) 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.