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It is alleged in this complaint that Romeo experienced a constrained supply of battery cells, which was contrary to Romeo’s representations: (1) Romeo used only two suppliers of battery cells, not four; (2) the future potential risks that Romeo warned of, which concerned disruption of supply or shortage, had already occurred, already negatively affecting Romeo business, operations and business prospects; (3) Romeo did not in fact have the battery cell inventory needed to accommodate end-user demand and ramp up production in 2021; (4) Romeo’s supply constraint was a material hindrance to revenue growth; and (5) Romeo’s supply chain for battery cells was not hedged, but in fact at risk and beholden to their only two battery cell suppliers and the spot market for their 2021 inventory. The lawsuit claims that investors suffered damages when the true details entered the market.