According to the lawsuit, the IPO Registration Statement featured false and/or misleading statements and/or failed to disclose that:
- the number of virtual visits clients were undertaking utilizing LifeStance Health was decreasing as the COVID-19 lockdowns were being lifted, thereby flatlining LifeStance Health’s out-patient/virtual revenue growth;
- the percentage of in-person visits clients were undertaking utilizing LifeStance Health was increasing as the COVID-19 lockdowns were being lifted, thereby causing LifeStance Health’s operating expenses to increase substantially;
- LifeStance Health had lost a large number of physicians due to burn-out and, as a result, its physician retention rate had fallen significantly below the 87% highlighted in the IPO’s registration statement and LifeStance Health had been expending additional costs to onboard new physicians who were less productive than the outgoing physicians they were replacing; and
- as a result, LifeStance Health’s business metrics and financial prospects were not as strong as the IPO’s registration statement represented.
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