Peizer established a Rule 10b5-1 trading plan in May 2021 to sell Ontrak stock, despite knowing that the company's relationship with its then-largest customer, which represented more than half its revenue, was tenuous. He sold nearly 600,000 of Ontrak shares worth more than $19.2 million before adopting a second Rule 10b5-1 trading plan in August 2021, which prompted him to sell 45,000 more shares of stock worth more than $1.9 million. The complaint alleges that Peizer avoided more than $12.7 million in losses by executing the two trading plans.