The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) the purported agreement with Energy Storage Industries Asia Pacific (“ESI”) was in fact an undisclosed related party transaction because ESI was a de-facto subsidiary of ESS masquerading as third-party client; (2) ESS misled investors with their partnership announcement to signal business success to investors; and (3) as a result, Defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.