Waterdrop 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 Waterdrop had achieved a substantial portion of its historical revenue growth through illicit means that ran afoul of Chinese rules and regulations governing the insurance industry;
(b) that Waterdrop had been ordered by the Chinese government to shut down its mutual aid platform because of its failure to comply with Chinese law;
(c) that Waterdrop was under investigation by regulatory authorities for continued violations of Chinese law;
(d) that, as a result of (a)-(c) above, there existed a material undisclosed risk and substantial likelihood that Waterdrop would face severe adverse actions by regulatory authorities following the IPO;
(e) that Waterdrop’s operating losses had increased more than four-fold in the first quarter of 2021 as a result of the cessation of its mutual aid business and rapidly growing customer acquisition costs; and
(f) that, as a result of (a)-(e) above, the Registration Statement’s representations regarding Waterdrop’s historical financial and operational metrics and purported market opportunities did not accurately reflect the actual business, operations, and financial results and trajectory of the Company in the lead up to the IPO, were materially false and misleading, and lacked a factual basis.