Allegations
(a) a material portion of Tuya’s China-based customers were engaged in the widespread and systematic manipulation of reviews and product offerings in violation of Amazon.com’s terms of use; (b) prior to the initial public offering, a consumer investigation and data breach had exposed an illicit fake review scheme being perpetrated by many of Tuya’s clients, among others, which included, inter alia, the exposure of 13 million records of organized fake review scams linked to over 200,000 Amazon account profiles; (c) as a result of (a) and (b) above, there was a substantial risk that a material portion of Tuya’s significant customers would be barred from using Amazon.com’s platform, negatively impacting Tuya’s business, revenue, earnings, and prospects; and (d) as a result of (a)-(c) above, the registration statement’s representations regarding Tuya’s historical financial and operational metrics and purported market opportunities and expected growth did not accurately reflect the actual business, operations, financial results, and trajectory of the Company at the time of the initial public offering, and such statements were materially false and misleading and lacked a reasonable factual basis.