The alleged false and misleading statements and omissions include, but are not limited to, that: (i) the Company was engaged in improper anti-competitive practices with its suppliers and other third parties in violation of applicable regulations; (ii) the Company had improperly adjusted search algorithms and manipulated product reviews on its marketplace platform in order to prioritize its own private-label branded products over those of other sellers and merchants, to the detriment of consumers, merchants, and suppliers; (iii) unbeknownst to its Rocket WOW members, Coupang was selling products to non-member customers at lower prices than those offered to its Rocket WOW members; (iv) the Company subjected its workforce to extreme, unsafe, and unhealthy working conditions;  (v) all of the above illicit practices exposed the Company to a heightened, but undisclosed, risk of reputational and regulatory scrutiny that would harm the Company’s critical relationships with consumers, merchants, suppliers, and the workforce; and (vi) the Company’s lower prices, historical revenues, competitive advantages, and growing market share were the result of systemic, improper, unethical, and/or illegal practices, and, thus, unsustainable.