The filed complaint alleges that defendants made false statements and/or concealed that: (1) Allbirds was overemphasizing products that extended beyond the Company’s core offerings; (2) the Company’s non-core products had a narrower appeal and were not resonating with customers as well as the Company’s core products; (3) Allbirds was underinvesting in its core consumers’ favorite products to push the Company’s newer products with narrower appeal; (4) underinvesting in Allbirds’ core products was negatively impacting the Company’s sales; and (5) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects, were materially misleading and/or lacked a reasonable basis.