The Complaint alleges that the registration statement and prospectus used to effectuate the Company’s Offering were false and misleading and omitted to state that, at the time of the Offering: (1) Coinbase required a sizeable cash injection; (2) Coinbase’s platform was susceptible to service-level disruptions, which were increasingly likely to occur as the Company scaled its services to a larger user base; and (3) as a result of the foregoing, the positive statements about the Company’s business, operations and prospects were materially misleading and/or lacked a reasonable basis.