The filed complaint alleges that defendants made false statements and/or concealed that: (i) defendants had downplayed the true scope and severity of risks that Xiao-I faced due to certain of its Chinese shareholders’ non-compliance with foreign investment enterprises established by way of round-tripping, including the Company’s inability to use offering proceeds for intended business purposes; (ii) Xiao-I had failed to comply with Generally Accepted Accounting Principles in preparing its financial statements; (iii) defendants had overstated Xiao-I’s efforts to remediate material weaknesses in the Company’s financial controls; (iv) Xiao-I was forced to incur significant R&D expenses to effectively compete in the AI industry; (v) Xiao-I had downplayed the significant negative impact that such expenses would have on the Company’s business and financial results; (vi) accordingly, Xiao-I overstated its AI capabilities, R&D resources, and overall ability to compete in the AI market; (vii) as a result of all the foregoing, there was a substantial likelihood that Xiao-I would fail to comply with the NASDAQ’s Minimum Bid Price Requirement; and (viii) as a result, the offering documents and defendants’ public statements throughout the class period were materially false and/or misleading and failed to state information required to be stated therein.