According to the complaint, during the class period, defendants created the false impression that they possessed reliable information pertaining to the Company's projected revenue outlook and anticipated sales. In truth, Fly-E's optimistic revenue goals and demand for its EV products and services fell short of reality; defendants continually praised Fly-E's brand reputation in the industry, cost reductions and favorable pricing from suppliers as a key component for Fly-E's ability to grow its sales network, while simultaneously minimizing risks associated with its lithium battery, supply chain changes and the regulatory environment and possible demand fluctuations for its E-Bikes and E-Scooters.