The filed complaint alleges that defendants made false statements and/or concealed that: (1) Defendant Mmobuosi fabricated biographical claims about himself; (2) Tingo had photoshopped its logo onto pictures of airplanes it did not own; (3) Tingo inflated its food division margins; (4) Tingo published misleading images of its planned Nigerian food processing facility and overstated its progress on the facility’s construction; (5) Tingo inflated its food inventory; (6) Tingo did not have relationships with the two farming cooperatives it claimed; (7) Tingo did not generate $128 million in revenue for its handset leasing, call and data segments as it claimed; (8) Tingo’s Mobile operation in Nigeria was delinquent on its tax obligations; (9) Tingo photoshopped its logo over pictures from a different point of sale system operator’s website; (10) Tingo did not generate $125.3 million in revenue from its online marketplace called NWASSA; (11) Tingo’s agricultural export business was not on track to deliver $1.34 billion in exports by Q3 2023; (12) Tingo lacked effective controls over accounting and financial reporting; and (13) as a result of the foregoing, defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.