Allegations
(1) the Transportation Security Administration ("TSA") and Centers for Medicare and Medicaid Services ("CMS") contracts, which constituted a majority of the Company’s future revenues, were not on track to commence as represented at the end of 2021 and in 2022; (2) Defendants lacked a reasonable basis and sufficient visibility to provide and affirm the Company’s 2021 guidance in the face of the uncertainty surrounding the TSA and CMS contracts; (3) COVID-19- and hacking scandal-related headwinds were throwing off the timing for performance of the TSA and CMS contracts and their associated revenues; (4) as a result, the guidance provided by Defendants was not in fact “conservative”; (5) as a result of the delays, Telos would be forced to dramatically reduce its revenue estimates; and (6) as a result of the foregoing, Defendants’ statements about Telos’ business, operations, and prospects, were materially false and/or misleading and/or lacked a reasonable basis.