The Complaint alleges that the IPO’s registration statement documents were materially false and misleading because they failed to disclose that: (i) a material portion of Tuya’s China-based customers were engaged in the widespread and systematic manipulation of reviews and product offerings in violation of Amazon.com’s terms of use; (ii) prior to the IPO, a consumer investigation and data breach had exposed an illicit fake review scheme being perpetrated by many of Tuya’s clients, among others, which included, among other things, the exposure of 13 million records of organized fake review scams linked to over 200,000 Amazon account profiles; (iii) as a result, there was a substantial risk that a material portion of Tuya’s significant customers would be barred from using Amazon.com’s platform, negatively impacting Tuya’s business, revenue, earnings, and prospects; and (iv) as such, the IPO’s registration statement’s representations regarding Tuya’s historical financial and operational metrics and purported market opportunities and expected growth did not accurately reflect the actual business, operations, financial results, and trajectory of Tuya at the time of the IPO.