Peloton Interactive, Inc.

(1) in addition to the tragic death of a child, Peloton’s Tread+ had caused a serious safety threat to children and pets as there were multiple incidents of injury to both; (2) safety was not a priority to Peloton as defendants were aware of serious injuries and death resulting from the Tread+, yet did not recall or suggest a halt of the use of the Tread+; (3) as a result of the safety concerns, the U.S. Consumer Product Safety Commission ("CPSC") declared that the Tread+ posed a serious risk to public health and safety and urgently recommended that consumers with small children cease using the Tread+; (4) the CPSC also found a safety threat to Tread+ users if they lost their balance; and (5) as a result of the foregoing, defendants’ statements about Peloton’s business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.