Allegations against INS include that: (1) Defendant Petit, the "financial expert" on the Company's Audit Committee, engaged in accounting fraud as the CEO of MiMedx Group; (2) the Company's CEO, Defendant Strange, engaged in undisclosed related-party transactions with Defendant Petit and others and had an undisclosed personal relationship with the Company's auditor; (3) the Company had its employees set up or take control of shell companies in Asia so they could partake in undisclosed related-party transactions for the purpose of either fabricating revenue for the Company and/or siphoning money out of the Company; and (4) as a result, Defendants' statements about Intelligent Systems' business, operations, and prospects were materially false and/or misleading and/or lacked a reasonable basis at all relevant times.