According to the Complaint, Amyris purports to be an industrial biotechnology company that manufactures and
sells natural, sustainably-sourced products in health and wellness, clean beauty, and flavor and fragrance markets.

The Complaint alleges that throughout the Class Period, Defendants made false and/or misleading statements, as well as failed to disclose material adverse facts about the Company's business, operations, and prospects. Specifically, the Complaint alleges that Defendants made false and/or misleading statements and/or failed to disclose: (1) that the Company lacked sufficient resources to accurately account for certain transactions; (2) that, as a result, there was a material weakness in the Company's internal controls over financial reporting; (3) that, as a result, the Company would be unable to timely file its annual report; and (4) that, as a result of the foregoing, Defendants' positive statements about the Company's business, operations, and prospects were materially misleading and/or lacked a reasonable basis.