According to the Complaint, Tufin Software Technologies Ltd. develops, markets, and sells software-based solutions primarily in the United States, Europe, and Asia.

On April 11, 2019, Tufin filed a prospectus for its initial public offering (the "IPO") on Form 424B4, which incorporated and formed part of the April Registration Statement (the "April Prospectus" and collectively, with the April Registration Statement, the "IPO Offering Documents"), issuing 7,700,000 ordinary shares to the investing public at $14.00 per share (the "IPO Price"), for anticipated gross proceeds of $107,800,000.

On December 2, 2019, the Company filed a second registration statement with the SEC on Form F-1, which was declared effective on December 5, 2019 (the "December Registration Statement"). Thereafter, on December 5, 2019, Tufin filed a prospectus for its secondary offering (the "SPO") on Form 424B4, which incorporated and formed part of the December Registration Statement (the "December Prospectus" and collectively, with the December Registration Statement, "SPO Offering Documents"), issuing an additional 4,279,882 ordinary shares to the investing public at $17.00 per share (the "SPO Price"), for anticipated gross proceeds of $72,757,994.

The Complaint alleges that Defendants violated provisions of the Securities Act by issuing false and misleading registration statements and prospectuses in connection with both its IPO and its SPO. Specifically, the Complaint alleges that Defendants misled investors with respect to the Company's North American business, customer relationships and growth metrics, and the fact that Tufin's business was deteriorating, and, as a result, Tufin's representations regarding its sustainable financial prospects were overly optimistic—all of which was known to, and concealed by, Defendants at the time of the IPO and SPO.