The filed complaint alleges that defendants made false statements and/or concealed that: (1) defendants overstated the progress of the Company’s fundraising activities; (2) defendants overstated the likelihood and/or feasibility of obtaining sufficient funding to continue operations; (3) defendants failed to sufficiently disclose the imminent insolvency of the Company and its subsidiaries; and (4) that, 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.