The Complaint alleges the Registration Statement's representations were materially inaccurate, misleading, and/or incomplete because they failed to disclose, among other things, that the R1T and R1S were underpriced to such a degree that Rivian would have to raise prices shortly after the IPO and that these price increases would tarnish Rivian’s reputation as a trustworthy and transparent company and would put a significant number of the existing backlog of 55,400 preorders along with future preorders in jeopardy of cancellation. As a result, the Complaint alleges the price of the Company's shares was artificially and materially inflated at the time of the Offering.