The Complaint alleges that the IPO's Registration Statement failed to disclose that: (a) PRC authorities were in the process of implementing sweeping new regulatory reforms on the private education industry in China including, among others, prohibitions on: (i) profit-making by private education companies, (ii) engaging in core-curriculum tutoring on weekends and vacations, and (iii) capital-raising by companies like Zhangmen Education; (b) the known risks, events, and uncertainties noted in the Registration Statement were reasonably likely to have a material adverse effect on Zhangmen Education's business; and (c) based on the foregoing, the statements in the Registration Statement concerning Zhangmen Education's historical financial performance, market demand, and industry trends were materially incomplete, inaccurate, and misleading.