On March 24, 2021, Defendants filed a proxy statement with the United States Securities and Exchange Commission in connection with the Proposed Transaction. The Complaint alleges that the Proxy Statement omitted material information with respect to the Proposed Transaction, rendering the Proxy Statement false and misleading. Specifically, the Complaint alleges that Defendants: (i) used materially deceptive “risk factor” statements to withhold the truth about problems facing Lion Electric, including supply chain problems with its suppliers and sub-suppliers; (ii) misled NGA’s stockholders about Lion Electric’s prospects using grossly unrealistic financial projections; and (iii) failed to provide NGA stockholders with the “net cash” value of their shares – the key disclosure about the fundamental purchasing power their NGA shares represented.