Recent Security Class Actions

According to the Complaint, Lincoln National Corporation is a holding company which operates multiple insurance and retirement businesses through subsidiary companies. The Company provides products and services and reports results through four segments: Annuities, Life Insurance, Group Protection, and Retirement Plan Services.The Complaint alleges that throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operations, and prospects. Specifically, the Complaint alleges Defendants failed to disclose to investors: (1) that the Company was experiencing a decline in its variable universal life insurance (“VUL”) business; (2) that, as a result, the goodwill associated with the life insurance business was overstated; (3) that, as a result, the Company’s policy lapse assumptions were outdated; (4) that, as a result, the Company’s reserves were overstated; (5) that, as a result, the Company’s reported financial results and financial statements were misstated; and (6) 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.

According to the Complaint, Global Cord Blood Corporation, together with its subsidiaries, provides umbilical cord blood storage and ancillary services in the in the Beijing Municipality, Guangdong Province, and Zhejiang Province of the People’s Republic of China. On April 29, 2022, after the market closed, Global Cord announced that it had entered into a Material Definitive Agreement to acquire Cellenkos Inc. for over $1 billion, including $664 million in cash and 114 million Global Cord shares— roughly the same number of the Company’s shares that were already outstanding (the “Transaction”). The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business, operations, and prospects. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) Global Cord employed a capital allocation strategy designed to reserve funds for Company insiders and related parties rather than for the benefit of Company shareholders; (ii) Global Cord's decisions to reject multiple going private offers and enter into the Transaction were nothing more than self-serving and conflicted attempts by Defendants to divert company funds to corporate insiders and related parties; (iii) Defendants had fundamentally misrepresented to investors Global Cord's approach to capital allocation, strategic investments, acquisitions, and related party transactions as a result of the misappropriation by Defendant Kam and his entities of hundreds of millions of dollars from the Company; and (iv) as a result, the Company's public statements were materially false and misleading at all relevant times.

According to the Complaint, GoodRx Holdings, Inc. operates a price comparison platform for prescription drugs which, in many cases, offers consumers access to lower prices (through discount codes and coupons) for their medications. GoodRx generates most of its revenue from contracts with pharmacy benefit managers (“PBMs”) who agree to pay GoodRx a commission on prescription drug purchases made by consumers who use GoodRx’s discount codes and coupons at participating pharmacies. GoodRx also generates a portion of its revenue from subscription plans like the “Kroger Rx Savings Club,” which provides “access [to] lower prescription prices at” pharmacies operated by The Kroger Co.The Complaint alleges that, throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose that: (1) while Kroger accounted for less than 5% of the pharmacies accepting GoodRx discounts, Kroger was responsible for nearly 25% of GoodRx’s total prescription transactions revenue (the Company’s primary revenue stream); and (2) Kroger could unilaterally cease accepting GoodRx discounts, cutting off some or all of GoodRx’s revenues for purchases at Kroger’s pharmacies; and (3) as a result, Defendants’ representations about the Company’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis.

According to the Complaint, Sharecare, Inc. was founded in 2009 to develop an interactive health and wellness platform. Sharecare’s virtual health platform is designed to help people, patients, providers, employers, health plans, government organizations, and communities optimize individual and population-wide well-being by driving positive behavior change.The Complaint alleges that Defendants throughout the Class Period made materially false and/or misleading statements and/or failed to disclose that: (1) Sharecare lacked adequate internal controls; and (2) as a result, Defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all times.

According to the Complaint, Rivian Automotive, Inc., together with its subsidiaries, designs, develops, manufactures, and sells EVs and accessories. The Company’s products include, among others, the R1T, a two-row, five-passenger pickup truck, and the R1S, a three-row, seven passenger sport utility vehicle, both of which are marketed as consumer EVs, as well as the Electric Delivery Van (“EDV”), which is marketed as a commercial EV. Rivian sells its products directly to customers in both the consumer and commercial markets.The Complaint alleges that, throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business, operations, and prospects. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) Rivian had overstated demand for its products, as well as its ability to withstand negative, near-term macroeconomic impacts; (ii) accordingly, Rivian's business was experiencing reduced demand and increased customer cancellations as a result of, inter alia, high interest rates; (iii) as a result, Rivian's order bank had significantly deteriorated; (iv) all the foregoing was likely to, and did, negatively impact the Company's anticipated earnings and vehicle production targets for 2024; and (v) as a result, the Company's public statements were materially false and misleading at all relevant times.

According to the Complaint, Doximity, Inc.'s business is based upon a social media-like platform that provides connections between medical professionals, offers medical professionals valuable information to assist them in treating patients, and helps medical professionals schedule patient visits.The Complaint alleges that, throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts, about the Company’s business and operations. Specifically, the Complaint alleges Defendants repeatedly touted the Company’s business prospects and the sustainability of the Company’s revenue growth and profitability, while downplaying the impact of competition and tightening macroeconomic conditions on the Company and Doximity’s reliance on “upselling” products and services (such as additional advertising) to existing customers to sustain the Company’s performance and future growth.

According to the Complaint, AST SpaceMobile, Inc., together with its subsidiaries, seeks to develop and provide access to a space-based cellular broadband network for smartphones in the United States distributed through a constellation of Low Earth Orbit satellites. The Company purports to be in the advanced stages of assembling and testing its first generation of commercial BlueBird satellites, the “Block 1 BlueBird” satellites, in advance of launching its space-based cellular broadband network. The Complaint alleges that throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operations, and prospects. Specifically, the Complaint alleges Defendants failed to disclose to investors: (1) that production of the Company’s five Block 1 BlueBird satellites had been negatively impacted by two suppliers of key subsystems; (2) that a result, the Company had not substantially completed the production of the Block 1 BlueBird satellites; (3) that, as a result, the Company’s five Block 1 BlueBird satellites were not on track to launch in the first quarter of 2024; 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.

According to the Complaint, Perion Network Ltd. is a global technology company that provides digital advertising products and services. Perion’s most significant search partner and largest source of revenue is Microsoft. The Company entered into its first agreement with Microsoft in 2010 and then entered into its current search services agreement in November 2020, which is effective from January 2021 through December 2024. Perion’s current agreement with Microsoft accounted for 37%, 35%, and 34% of Perion’s revenue in 2021, 2022 and 2023, respectively.The Complaint alleges that throughout the Class Period, Defendants made false and/or misleading statements, as well as failed to disclose material facts, including that: (1) Perion’s search advertising business was not a reliable and significant growth driver and was in fact in decline; (2) Perion’s long-term relationship with Microsoft and search services agreement would not provide stability for Perion’s search advertising business; (3) there was an increased risk of Microsoft acting to unilaterally change its advertising pricing and mechanisms to the detriment of Perion while the search services agreement was in place; (4) Perion’s AI technology and Microsoft’s investment in ChatGPT would not protect or grow Perion’s search advertising revenue; and (5) based on the foregoing, Defendants lacked a reasonable basis for their positive statements about Perion’s search advertising business and related financial results, growth, and prospects.

According to the Complaint, VinFast Auto Ltd. describes itself as “an innovative, full-scale mobility platform focused primarily on designing and manufacturing premium EVs (“electric vehicles”), e-scooters, and ebuses. Founded and headquartered in Vietnam, the Company has since expanded its sales and operations into other markets, including Southeast Asia, North America, and Europe. On May 12, 2023, VinFast announced that it had entered into a business combination with Black Spade, which purportedly "runs a global portfolio consisting of a wide spectrum of cross-border investments, and consistently seeks to add new investment projects and opportunities to its portfolio."On June 15, 2023, VinFast filed a registration on Form F-4 with the SEC in connection with the Merger, which, after several amendments, was declared effective by the SEC on July 28, 2023. Also on July 28, 2023, the Company filed a joint prospectus and proxy statement on Form 424B3 with the SEC in connection with the Merger, which incorporated and formed part of the Registration Statement.On August 14, 2023, the Company consummated the Merger whereby, among other things, Merger Sub merged with and into Black Spade, with Black Spade surviving the transaction as a wholly owned subsidiary of the Company. Prior to the Merger, the Company operated as a publicly traded special purpose acquisition company.The Complaint alleges that the Offering Documents were negligently prepared and, as a result, contained untrue statements of material fact or omitted to state other facts necessary to make the statements made not misleading and were not prepared in accordance with the rules and regulations governing their preparation. Additionally, the Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business, operations, and prospects; specifically, that the Offering Documents and Defendants made false and/or misleading statements and/or failed to disclose that: (i) VinFast lacked sufficient capital to execute its purported growth strategy; (ii) VinFast would be unable to meet its 2023 delivery targets; (iii) accordingly, VinFast had overstated the strength of its business model and operational capabilities, as well as its post-Merger business and/or financial prospects; and (iv) 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.

According to the Complaint, QuidelOrtho Corporation manufactures and sells diagnostic healthcare products in the areas of immunoassay and molecular testing, clinical chemistry, and transfusion medicine. Since 2020, when COVID-19 became a pandemic, QuidelOrtho’s respiratory business began generating substantial revenue from the sale of COVID-19 detection tests. The Complaint alleges that throughout the Class Period, Defendants misled investors by making statements that were false and misleading when made because they knew or deliberately disregarded and failed to disclose the following adverse facts about QuidelOrtho’s business, operations, and prospects: (a) that QuidelOrtho sold more COVID-19 tests to its distributors and pharmacy chain customers than they could resell to healthcare providers and end customers; (b) that excess inventories of COVID-19 tests existed throughout the supply chain; (c) that, as a result of (a)-(b), QuidelOrtho’s distributors and pharmacy chain customers were poised to significantly reduce their COVID-19 test orders; (d) that undisclosed problems created a heightened risk that the Savanna RVP4 Test would experience a delayed commercial launch in the United States; and (e) that, as a result of (a)-(d), Defendants lacked a reasonable basis for their positive statements about QuidelOrtho’s business, financials, and growth trajectory.