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It is alleged in this complaint that Arcimoto made false and misleading statements to the market. Out of 422 alleged pre-orders for Arcimoto’s Fun Utility Vehicles, only 19 units were delivered to customers. Arcimoto failed to disclose to its customers that almost all of its FUVs were subject to a safety recall. R-Key-Moto, Arcimoto’s largest customer, was actually an undisclosed related party owned by insider FOD Capital, LLC. In addition, Arcimoto’s partnership with HULA was an undisclosed related party transaction. Arcimoto’s public statements were false and materially misleading, based on these facts. Investors suffered damages when the market learned the truth about Arcimoto.