The Complaint alleges that throughout the Class Period, Defendants failed to disclose that: (i) the published epitope mapping, structural studies, and sequence analyses which Defendants had used to claim ADG20 was effective against the Omicron variant were insufficient, unreliable, and inadequate to make claims of effectiveness of ADG20 against Omicron; (ii) that Defendants’ claims regarding ADG20’s efficacy against Omicron lacked a reasonable factual basis; and (iii) ADG20 was over 300 times less effective against the Omicron variant as compared to its effectiveness against previous variants.