The Complaint allege that Defendants made false and/or misleading statements and/or failed to disclose that: (i) Uber had defective disclosure controls and procedures; (ii) Uber concealed and/or downplayed the full scope and severity of its prior misconduct, including, inter alia, the extent to which it secretly lobbied government officials and politicians to bypass legal and regulatory requirements, as well as knowingly risked the safety of Uber drivers, to fuel the Company's global growth; (iii) as a result, Uber's present global footprint and market share is in significant part the byproduct of previously undisclosed, unsustainable, and illegal business practices; (iv) all the foregoing, once revealed, was likely to negatively impact Uber's reputation, as well as subject the Company to a heightened risk of governmental and regulatory scrutiny and enforcement action; and (v) as a result, the Company's public statements were materially false and misleading at all relevant times.