Allegations
(a) a material percentage of the Company's AcQMap imaging and mapping systems under evaluation had been randomly installed at sites with little, if any, consideration given to whether the healthcare providers at the selected locations were likely to adopt, or desire, the Company’s products; (b) a material percentage of the AcQMap systems under evaluation had been installed in locations where the Company did not possess the infrastructure necessary to appropriately educate, train, and support medical service providers on the system’s operations; (c) as a result of (a) and (b) above, defendants were in the process of designing a strategic plan to terminate and relocate approximately 20% of then-existing AcQMap systems evaluation arrangements; (d) the Company’s management discussion and analysis was materially false and misleading and failed to disclose that the termination and relocation of approximately 20% of existing AcQMap systems evaluation arrangements was reasonably likely to have a material adverse effect on the Company’s 2021 financial results; and (e) the Company’s risk factor discussions were materially false and misleading and made reference to potential risks without disclosing that such risks were then-existing or adequately describing the specific nature of the risks then facing the Company.