The filed complaint alleges that defendants made false statements and/or concealed that: (1) UP Fintech’s business was, quite simply, illegal as it related to operations in China as a result of its failure to obtain the proper licenses; (2) UP Fintech did not fully disclose to investors that it was engaging in unlawful activity and instead characterized the applicable Chinese laws as ambiguous; (3) the foregoing subjected the Company to a heightened risk of regulatory enforcement; and (4) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.