According to the Complaint, Defendants made false and/or misleading statements and/or failed to disclose that: (1) Defendant Russell was engaged in undisclosed conduct that would make him the subject of an inquiry by the Audit Committee of the Board of Directors; (2) this conduct created material risk that Defendant Russell would be released from his positions at the Company; (3) Luminar’s loss of Russell as an employee would then create material
risk of adversely affecting the Company’s business by making it more difficult to, compete with other market participants, manage R&D activities, and retain existing customers or cultivate new ones. Further, negative public perception and negative news related to Defendant Russell could also adversely affect Luminar’s brand, relationships with customers, or standing in the industry; (4) accordingly, Luminar had no reasonable basis to provide and/or maintain the Company’s financial guidance; and (5) as a result, Defendants’ public statements were materially false and/or misleading at all relevant times.