The Complaint alleges that throughout the class period, Gemini represented that it vetted “accredited” institutional borrowers through a risk management framework that reviewed collateralization, cash flow, balance sheet strength, and financial statements. Gemini stated that its lending partner’s loans were “overcollateralized,” and that its risk team conducted ongoing analysis of borrower’s financial condition. Gemini also suggested that Genesis was one of several third-party institutional borrowers, when in fact Genesis was the sole borrower for all Gemini Earn assets.