The alleged false and misleading statements and omissions include, but are not limited to, that: (i) the Company’s out-patient/virtual revenue growth was negatively affected by a decrease in virtual visits after COVID-19 lockdowns were lifted; (ii) an increasing number of in-person visits post-lockdown resulted in substantial increases to operating expenses; (iii) its physician retention rate had fallen significantly below the 87% highlighted in the IPO’s registration statement leading to additional costs to bring on new physicians, who were less productive than the outgoing physicians they were replacing; and (iv) as a result, LifeStance Health’s business metrics and financial prospects were not as strong as the IPO’s registration statement represented.