Summary: This is a federal securities class action lawsuit filed by Albert Nicholas Horvath against Rivian Automotive, Inc. and various individuals and financial institutions. The lawsuit alleges violations of federal securities laws, claiming that Rivian and its officers, directors, and underwriters made false and misleading statements and failed to disclose material adverse facts about the company's business and operations. The plaintiff specifically alleges that the defendants misrepresented the number of preorders for Rivian's electric vehicles and the company's production and delivery capabilities. The lawsuit covers the period between November 10, 2021, and March 10, 2022, as well as purchases of Rivian common stock made during the company's November 2021 initial public offering. The plaintiff seeks damages on behalf of a class of individuals and entities who purchased Rivian common stock during the specified period. The defendants named in the lawsuit include Rivian, its CEO Robert J. Scaringe, and another executive named Claire McDonough. The lawsuit alleges that the defendants violated federal securities laws by making false and misleading statements in connection with Rivian's IPO. The lawsuit claims that Rivian made false and misleading statements in its Registration Statement and subsequent communications regarding its production capabilities and business prospects. The plaintiffs argue that Rivian had a duty to disclose known trends and uncertainties, including its failure to meet production targets and the need for price increases, in its Registration Statement. The plaintiffs seek damages on behalf of investors who purchased Rivian's securities during the relevant period, claiming that they suffered financial losses as a result of Rivian's alleged false and misleading statements. The complaint alleges that Rivian reassured investors about its strong growth prospects despite acknowledging production issues and inflationary price pressure. However, it is alleged that Rivian's statements were false and misleading. The lawsuit claims that on December 17, 2021, Rivian's stock price fell over 10% after it was revealed that the company had produced and delivered far fewer vehicles than previously stated. Additionally, on March 1, 2022, Rivian announced significant price increases for its vehicles, including charging extra for previously standard features, leading to customer outrage and cancellations of preorders. Following the price increase announcement, Rivian's stock price fell over 13%. However, two days later, Rivian backtracked on the price increases for existing preorders, causing a further decline in its stock price. On March 10, 2022, Rivian announced disappointing financial results and lower production expectations due to supply chain constraints, resulting in another decline in the company's stock price. The lawsuit alleges that Rivian's admissions regarding production and pricing issues validate concerns raised by a former executive prior to the company's IPO, who had raised concerns about unrealistic manufacturing and delivery dates, vehicle quality, and underpricing. The lawsuit seeks class action status on behalf of all persons and entities who purchased Rivian common stock between November 10, 2021, and March 10, 2022, inclusive, as well as those who purchased stock pursuant to the company's November 2021 IPO, seeking damages for the financial losses suffered by the class members.