Allegations
(1) the Company had misrepresented the true educational background of its former CEO, Yang Jie; 2) Yang Jie had an outstanding arrest warrant in China, had committed forgery, and was the largest shareholder and VP of Finance for a Nasdaq-listed lending company, China Commercial Credit ("CCC"), which failed after reporting massive losses; (3) there existed material related party transactions with SOS Information Technology New York Inc. (where Jie’s wife was Vice President) and Rich Trading, whose CEO was defendant Lei Nie, the husband of Singularity CFO Tuo Pan; (4) Singularity director John Levy had been a director at CCC from January 2013 through December 2016 as CCC failed amidst detailed allegations that Jie, when he was an executive and shareholder in CCC, misappropriated assets; (5) the Company lacked adequate internal controls, and as a result had a heightened risk of scrutiny and was ultimately subject to a United States Attorney’s Office for the Southern District of New York and SEC investigation and action as well as a potential delisting by NASDAQ; and (6) as a result, the Company’s statements during the class period about the 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, and were materially false and misleading and lacked a factual basis.