The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business, operations, and compliance policies. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) the Company maintained deficient safety and structural controls related to its manufacturing of battery components; (ii) the foregoing deficiencies rendered Nikola's vehicles unsafe to operate and thus unusable, thereby raising the likelihood of a product recall; and (iii) as a result, the Company's public statements were materially false and misleading at all relevant times.