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It is alleged in this lawsuit that Zymergen’s Registration Statement was misleading and false and omitted to state that: (i) key customers had encountered technical issues, during the qualification process for Hyaline, including product shrinkage and incompatibility with customers’ processes; (ii) though the qualification process was critical in achieving market acceptance for Hyaline, as well as generating revenue, Zymergen lacked visibility into the qualification process; (iii) Zymergen overestimated demand for its products, as a result; and (iv) consequently, Zymergen’s product delivery timeline was reasonably likely to be delayed, in turn delaying generation of revenue..