According to the Complaint, Neonode Inc. develops optical touch and gesture control solutions for human-machine interface with devices and remote sensing solutions for driver and cabin monitoring features in automotive and other application areas.

The Complaint alleges that Defendants disseminated a materially incomplete proxy statement filed by Neonode Inc. with the United States Securities and Exchange Commission on August 20, 2020. The Proxy Statement scheduled a meeting of Neonode’s stockholders for September 29, 2020 to vote upon the following proposals, among others:

(1) To approve, for purposes of complying with Nasdaq Listing Rule 5635(d), the issuance of shares of common stock underlying Preferred Stock sold in Neonode’s August 5, 2020 private placement; [and]
(2) To approve, for purposes of complying with Nasdaq Listing Rule 5635(c), the issuance of shares of common stock underlying Preferred Stock sold to directors and an officer of Neonode in Neonode’s August 5, 2020 private placement[.]

The Complaint allges that the Proxy Statement omits material information, which renders the Proxy Statement false and misleading.