According to the Complaint, Nikola Corporation purports to operate as an integrated zero emissions transportation systems provider which designs and manufactures battery-electric and hydrogen-electric vehicles, electric vehicle drivetrains, vehicle components, energy storage systems, and hydrogen fueling station infrastructure.

The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) VectoIQ did not engage in proper due diligence regarding its merger with Nikola; (2) Nikola overstated its "in-house" design, manufacturing, and testing capabilities; (3) Nikola overstated its hydrogen production capabilities; (4) as a result, Nikola overstated its ability to lower the cost of hydrogen fuel; (5) Nikola's founder and Executive Chairman tweeted a misleading "test" video of the Company's Nikola Two truck; (6) the work experience and background of key Nikola employees had been overstated and obfuscated; (7) Nikola did not have five Tre trucks completed; and (8) as a result, Defendants' public statements were materially false and/or misleading at all relevant times.