Recent Security Class Actions

According to the Complaint, TMC the metals company Inc. f/k/a Sustainable Opportunities Acquisition Corp. is a Canadian deep-sea minerals exploration company focused on the collection, processing, and refining of polymetallic nodules found on the seafloor of the Clarion Clipperton Zone of the Pacific Ocean (the "CCZ"). The Company's purported mission is to supply metals for electric vehicle batteries with the least possible negative environmental and social impact.

On March 4, 2021, DeepGreen Inc. ("DeepGreen") announced that it had entered into a business combination agreement with Sustainable Opportunities Acquisition Corporation ("SOAC"), special purpose acquisition company ("SPAC") with a dedicated Environmental, Social, and Governance ("ESG") focus. Upon closing of the merger, the combined company was renamed TMC the metals company Inc.

The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) the Company had significantly overpaid to acquire Tonga Offshore Mining Limited ("TOML") to undisclosed insiders; (2) the Company had artificially inflated its Nauru Ocean Resources Inc. ("NORI") exploration expenditures to give investors a false scale of its operations; (3) the Company's purported 100% interest in NORI was questionable given prior disclosures to the International Seabed Authority ("ISA" or the "Authority") that NORI was wholly owned by two Nauruan foundations and that all future income from NORI would be used in Nauru; (4) Defendants had significantly downplayed the environmental risks of deep-sea mining polymetallic nodules and failed to adequately warn investors of the regulatory risks faced by the Company's environmentally risky exploitation plans; (5) the Company's private investment in public equity ("PIPE") financing was not fully committed and, therefore, the Company would not have the cash necessary for large sale commercial production; (6) as a result of the foregoing, the Company's valuation was significantly less than Defendants disclosed to investors; and (7) as a result, Defendants' public statements were materially false and/or misleading at all relevant times.