This is a class action lawsuit filed on behalf of plaintiff Thomas Lamontagne, who purchased or otherwise acquired shares of Tesla common stock at prices artificially inflated by Defendants’ wrongful conduct. Plaintiff and the other members of the Class allege that they were misled by false and/or misleading statements and omissions made by Tesla and its senior officers and/or directors. They claim that they would not have purchased or otherwise acquired Tesla common stock, or would not have purchased or otherwise acquired them at the inflated prices that were paid, had they known the truth. The complaint alleges that the market price of Tesla common stock declined sharply upon public disclosure of the facts alleged. It is further alleged that the Individual Defendants, who were officers and/or directors of the company, had a duty to disseminate accurate and truthful information with respect to Tesla’s Autopilot and FSD technologies, and the safety of the company's vehicles. The complaint seeks damages for those who purchased or otherwise acquired Tesla common stock during the class period. The Individual Defendants are liable for the false statements and omissions alleged herein, and were provided with copies of Tesla’s SEC filings and press releases alleged herein to be misleading prior to or shortly after their issuance and had the ability and opportunity to prevent their issuance or to cause them to be corrected. The members of the Class are so numerous that joinder of all members is impracticable.