The filed complaint alleges that defendants made false statements and/or concealed that: (i) SeaStar and/or Legacy SeaStar had deficient compliance controls and procedures related to the Humanitarian Device Exemption (HDE) Application; (ii) accordingly, there were deficiencies with the HDE Application, the FDA was unlikely to approve the HDE Application in its present form, and the selective cytopheretic device’s regulatory prospects were overstated; (iii) the Company had downplayed the true scope and severity of deficiencies in its financial controls and procedures, while overstating Defendants’ efforts to remediate the same; (iv) accordingly, SeaStar had failed to properly account for the classification of certain outstanding warrants and the prepaid forward agreement; (v) as a result, SeaStar was likely to restate one or more of its previously issued financial statements; (vi) accordingly, SeaStar’s post-merger business and financial prospects were overstated; and (vii) as a result, the Company’s public statements were materially false and misleading at all relevant times.