The filed complaint alleges that defendants made false statements and/or concealed that: (1) Defendant and GDS CEO William Wei had engaged in undisclosed pre-paid forward sale contract transactions as early as May 2020; (2) this presented a risk of Defendant Huang’s ownership going below 5% of the Company’s outstanding shares; (3) if Huang’s ownership dipped below 5%, it would result in a change of control of the Company which, as the Company admitted, could result in disastrous consequences; and (4) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.