According to the Complaint, Luckin Coffee Inc. purports to engage in the retail sale of freshly brewed drinks, and premade food and beverage items in the People’s Republic of China. The Company offers freshly brewed drinks, including freshly brewed coffee and non-coffee drinks; and food and beverage items, such as light meals.

On April 22, 2019, the Company filed with the SEC a registration statement on Form F-1 for the IPO, which, after an amendment, was declared effective on May 16, 2019. On May 17, 2019, the Company filed a prospectus for the IPO on Form 424B4 (the “Prospectus”), which incorporated and formed part of the Registration Statement. The Registration Statement was used to sell to the investing public approximately 33 million Luckin ADSs, representing 264 million Luckin Class A common shares, at $17.00 per ADS.

The Complaint alleges that Defendants in the Registration Statement and throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) certain of Luckin’s financial performance metrics, including per-store per-day sales, net selling price per item, advertising expenses, and revenue contribution from “other products” were inflated; (2) Luckin’s financial results thus overstated the Company’s financial health and were consequently unreliable and would likely require restatement; and (3) as a result, the Company’s public statements were materially false and misleading at all relevant times. When the true details entered the market, the lawsuit claims that investors suffered damages.