According to the lawsuit, the Offering Documents were negligently prepared and, as a result, contained untrue statements of material fact or omitted to state other facts necessary to make the statements made not misleading and were not prepared in accordance with the rules and regulations governing their preparation. Additionally, throughout the Class Period, Defendants made materially false and misleading statements regarding the Company’s business, operations, and compliance policies. Specifically, the Offering Documents and Defendants made false and/or misleading statements and/or failed to disclose that:

• Bright Health had overstated its post-IPO business and financial prospects;
• Bright Health was ill-equipped to handle the impact of COVID-19-related costs;
• Bright Health was experiencing a decline in premium revenue because of a failure to capture risk adjustment on newly added lives;
• all the foregoing was reasonably likely to have a material negative impact on Bright Health’s business and financial condition; and
• as a result, the Offering Documents and Defendants’ public statements throughout the Class Period were materially false and/or misleading and failed to state information required to be stated therein.

No Class Has Been Certified. Until a class is certified, you are not represented by counsel unless you retain one. You may select counsel of your choice. You may also remain an absent class member and do nothing at this point. An investor’s ability to share in any potential future recovery is not dependent upon serving as lead plaintiff.

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