Allegations
(a) HyreCar had materially understated its insurance reserves; (b) HyreCar had systematically failed to pay valid insurance claims incurred prior to the Class Period; (c) HyreCar had incurred significant expenses transitioning to its new third-party insurance claims administrator and processing claims incurred from prior periods; (d) HyreCar had failed to appropriately price risk in its insurance products and was experiencing elevated claims incidence as a result; (e) HyreCar had been forced to dramatically reform its claims underwriting, policies and procedures in response to unacceptably high claims severity and customer complaints; and (f) as a result, HyreCar’s operations and prospects were misrepresented because the Company was not on track to meet the financial estimates provided to investors during the Class Period, and such estimates lacked a reasonable basis in fact, including HyreCar’s purported gross margin, EBITDA (earnings before interest, taxes, depreciation, and amortization), and net loss trajectories.