According to the Complaint, Kingold purports to design, manufacture, and sell 24-karat gold jewelry and Chinese ornaments in the People's Republic of China.

The Complaint alleges defendants made false and/or misleading statements and/or failed to disclose that: (1) Kingold used fake gold as collateral to fraudulently secure loans; (2) consequently, the Company would face creditor lawsuits and be delisted from the Shanghai Gold Exchange; and (3) 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.