The filed complaint alleges that defendants made false statements and/or concealed that: (i) the Company affirmatively misrepresented that its capital resources “will be adequate to meet our liquidity needs for at least the next 12 months”; (ii) omitted that there was substantial doubt about the Company’s ability to continue as a going concern; (iii) downplayed the nature and extent of the Company’s then-existing liquidity problems; (iv) omitted that the Company’s existing credit facilities were insufficient to satisfy its operational needs and that it was unable to obtain additional loans in the normal course of business; and (v) omitted that there was a material weakness in its internal control over financial reporting.