The
Roth Action alleges that, throughout the Class Period, the defendants failed to disclose that: (1) Emergent's Baltimore facility had a history of manufacturing issues increasing the likelihood for massive contaminations; (2) the Baltimore facility had received a series of Food and Drug Administration ("FDA") citations as a result of these contamination risks and quality control issues; (3) Emergent had been forced to discard millions of doses of COVID-19 vaccines after workers at the facility deviated from manufacturing standards; and (4) as a result of the foregoing, the defendants' public statements about Emergent's ability and capacity to mass manufacture multiple COVID-19 vaccines at its Baltimore facility were materially false and/or misleading and/or lacked a reasonable basis.