The filed complaint alleges that defendants made false statements and/or concealed that: (a) during the COVID-19 pandemic, the Company had lost highly skilled and experienced employees necessary to successfully complete the Company’s transition from its historic low mix, high volume production model to a high mix, low production model at its Monterrey facility; (b) the Company’s attempts to replace its GM center console production with more diversified, specialized products for a wider array of vehicle manufacturers and original equipment manufacturers, particularly in the EV space, had been plagued by production planning deficiencies, inventory shortages, vendor and supplier problems, and, ultimately, botched execution of the Company’s strategic plans; (c) the Company’s manufacturing systems at its critical Monterrey facility suffered from a variety of logistical defects, such as improper system coding, shipping errors, erroneous delivery times, deficient quality control systems, and failures to timely and efficiently procure necessary raw materials; (d) the Company had fallen substantially behind on the launch of new EV programs out of its Monterrey facility, preventing the Company from timely receiving revenue from new EV program awards; and (e) as a result of (a)-(d) above, the Company was not on track to achieve the 2023 diluted earnings per share guidance or the 3-year 6% organic sales CAGR represented to investors, and such estimates lacked a reasonable factual basis.