The Complaint alleges that throughout the Class Period, defendants made false and misleading statements and failed to disclose that: (i) Berkeley Lights’ flagship instrument, the Beacon, suffered from numerous design and manufacturing defects including breakdowns, high error rates, data integrity issues and other problems, limiting the ability of biotechnology companies and research institutions to consistently use the machines at scale; (ii) Berkeley Lights had received numerous customer complaints regarding the durability and effectiveness of Berkeley Lights’ automation systems, including complaints related to the design and manufacturing; (iii) the actual market for Berkeley Lights’ products and services was a fraction of the $23 billion represented to investors because of, among other things, the relatively high cost of Berkeley Lights’ instruments and consumables and inability to provide the sustained performance necessary to justify these high costs; and (iv) as a result, defendants’ statements to investors during the Class Period regarding Berkeley Lights’ business, operations and financial results were materially false and misleading.