According to the Complaint, Aqua Metals was purportedly formed to engage in the business of recycling lead through a novel process called "AquaRefining." The Company claims that it has focused its efforts on developing and testing the AquaRefining process, developing a business plan, raising working capital, and developing its initial lead acid battery, or LAB, recycling facility in the Tahoe Regional Industrial Center, in McCarran, Nevada.

According to the law firm press release, the complaint filed in this class action alleges that throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the Company's business, operations, and prospects. Specifically, Defendants failed to disclose: (1) that Aqua Metals' breaking and separating process was facing substantial obstacles due to AquaRefining's need for a much higher degree of separation than is normal in the industry; (2) that the Company's breaking and separating process was not operating reliably or efficiently; (3) that the breaking and separating obstacles and issues were negatively impacting the Company's output; (4) that the Company's four "operating modules" were being used primarily for experimentation, rather than production; (5) that module operators were assisting with lead removal; (6) that, as a result of the foregoing, the ramp up of the Company's recycling process was being significantly hindered and delayed; and (7) that, as a result of the foregoing, Defendants' statements about Aqua Metals' business, operations, and prospects, were materially false and/or misleading and/or lacked a reasonable basis.