The Complaint alleges that the registration statement supporting the IPO was false and/or misleading and/or failed to disclose that: (1) the Company would restate certain financials; (2) the Company's internal controls were inadequate; (3) the Company downplayed and obfuscated its internal controls issues; (4) as a result, the Company would engage in an independent investigation; (5) as a result of the investigation, the Company would, among other things, retain independent counsel and consultants, and delay its quarterly filings in violation of NYSE requirements of listing; (6) following the commencement of the investigation, the Company's CEO and CFO would leave the Company; and (7) as a result, Defendants' public statements were materially false and/or misleading at all relevant times.

Additionally, the Complaint alleges Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) the Company's internal controls were inadequate; (2) the Company downplayed and obfuscated its internal controls issues; (3) the Company did not properly construct or remediate its inadequate and ineffective internal controls; (4) contrary to the Company's statements, the Company was not remediating its internal controls; (5) as a result, the Company would engage in an independent investigation; (6) as a result of the investigation, the Company would, among other things, retain independent counsel and consultants, and delay its quarterly filings in violation of NYSE requirements of listing; (7) following the commencement of the investigation, the Company's CEO and CFO would leave the Company; and (8) as a result, Defendants' public statements were materially false and/or misleading at all relevant times.