The filed complaint alleges that defendants made false statements and/or concealed that: (i) Plug overstated its ability and/or efforts to mitigate the negative impacts that, among other things, supply chain constraints and material shortages could have or were having on the Company’s hydrogen business, as well as the sufficiency of its cash and capital to fund its operations; (ii) Plug continued to experience delays related to its green hydrogen production facility build-out plans, as well as in securing external funding sources to finance its growth plans; (iii) Plug downplayed the true scope and severity of all the foregoing when these issues were eventually revealed; (iv) as a result of all the foregoing, Plug also overstated the near-term prospects of its hydrogen production operations, as well as the viability of expanding those operations; and (v) as a result, the Company’s public statements were materially false and misleading at all relevant times.