Berkeley Lights, Inc.

According to the complaint, defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the company’s business, operations, and prospects. Specifically, defendants allegedly failed to disclose to investors:

(a) that Berkeley Lights’ flagship instrument, the Beacon, suffered from numerous design and manufacturing defects including breakdowns, high error rates, data integrity issues and other problems, limiting the ability of biotechnology companies and research institutions to consistently use the machines at scale;

(b) that Berkeley Lights had received numerous customer complaints regarding the durability and effectiveness of the company’s automation systems, including complaints related to the design and manufacturing detailed in (a), above, and described herein;

(c) that the actual market for Berkeley Lights’ products and services was a fraction of the $23 billion represented to investors because of, inter alia, the relatively high cost of the company’s instruments and consumables and inability to provide the sustained performance necessary to justify these high costs; and

(d) as a result of (a)-(c), above, defendants’ statements to investors during the class period regarding Berkeley Lights’ business, operations and financial results were materially false and misleading.