Allegations
(1) the Company had significantly overpaid for the Tongo Offshore Mining
Limited acquisition to undisclosed insiders; (2) the Company had artificially inflated its Nauru Ocean Resources Inc. (“NORI”) exploration expenditures to give investors a false scale of its operations; (3) the Company’s purported 100% interest in NORI was questionable given prior disclosures to the International Seabed Authority that NORI was wholly owned by two Nauruan foundations and that all future income from NORI would be used in Nauru; (4) Defendants had significantly downplayed the environmental risks of deep-sea mining polymetallic nodules and failed to adequately warn investors of the regulatory risks faced by the Company’s environmentally risky exploitation plans; (5) the Company’s PIPE financing was not fully committed and, therefore, the Company would not have the cash necessary for large sale commercial production; (6) as a result of the foregoing, the Company’s valuation was significantly less than Defendants disclosed to investors; and (7) as a result, Defendants’ public statements were materially false and/or misleading at all relevant times.