The filed complaint alleges that defendants made false statements and/or concealed that: (1) certain of the Company’s insiders had personal financial motives for acquiring GRAIL, Inc.; (2) contrary to Illumina’s attempts to discount Icahn’s criticism, Icahn had accurately concluded that insiders’ interests did not align with the Company’s best interests; and (3) 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.