The IPO offering documents were negligently prepared and, as a result, contained untrue statements of material fact or omissions. Specifically, the IPO offering documents made false and/or misleading statements and/or failed to disclose that:
- Expensify’s revenue growth was highly susceptible to structural and macroeconomic headwinds;
- as a result, Expensify overstated the efficacy of its business model and the likelihood it would meet the long-term growth projections touted in the Offering Documents;
- accordingly, Expensify’s post-IPO financial position and/or business prospects were overstated; and
- as a result, defendants’ statements about Expensify’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.
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