According to the lawsuit, defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that:

• Li-Cycle’s largest customer, Traxys North America LLC, is not actually a customer, but merely a broker providing working capital financial to the Company while Traxys tries to sell Li-Cycle’s product to end customers;
• the Company engaged in highly questionable related party transactions;
• the Company’s mark-to-model accounting is vulnerable to abuse and gave a false impression of growth;
• a significant portion of the Company’s reported revenues were derived from simply marking up receivables on products that had not been sold;
• the Company’s gross margins have likely been negative since inception;
• the Company will require an additional $1 billion of funding to support its planned growth (which is a figure greater than the Company raised via the merger); and
• as a result, defendants’ public statements were materially false and/or misleading at all relevant times.

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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