The Complaint alleges Defendants throughout the Class Period made materially false and/or misleading statements and/or failed to disclose that: (1) Brooge materially overstated its revenues because it never received any revenues from Al Brooge International Advisory LLC ("BIA"), as well as another fictitious customer; (2) Brooge engaged in a complex pattern of payments with BIA to create the illusion of revenues from BIA and another customer that had no knowledge of the fraud; (3) Brooge intentionally lied to its auditors and the Securities and Exchange Commission about its fraudulent activities; (4) Brooge lacked internal controls; and (5) as a result, Defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.