All persons and entities other than Defendants who purchased or otherwise acquired the common stock of Uber Technologies, Inc. pursuant and/or traceable to the Registration Statement issued in connection with Uber’s May 10, 2019 initial public stock offering, seeking to pursue remedies for Defendants violations of Sections 11, 12(a)(2), and 15 of the Securities Act of 1933.

Common stock of Uber Technologies, Inc.

The complaint alleges that Uber Technologies, Inc. engaged in a pattern of misrepresentations and omissions in their offering documents related to their initial public offering (IPO). Uber’s business model, which classified drivers as independent contractors, was allegedly illegal and posed significant undisclosed risks. The complaint details Uber’s history of operating without proper licenses and violating local laws in various markets, both domestically and internationally, in a strategy to outpace regulatory responses. Furthermore, Uber misrepresented the improvements in its toxic corporate culture and failed to disclose ongoing issues of sexual harassment and misconduct that contributed to a negative workplace environment. The allegations also highlight that Uber downplayed its passenger safety issues, including numerous incidents of sexual assaults and fatal accidents that were not properly reported to law enforcement. Uber’s Special Investigations Unit was reportedly more focused on protecting the company’s interests rather than passenger safety, maintaining a “three-strikes” policy that allowed problematic drivers to remain on the platform. Additionally, the complaint claims that Uber’s financial condition was worse than represented, with slowing growth and significant losses that were not adequately disclosed to investors. As a result of these alleged misrepresentations and omissions, the value of Uber’s common stock declined significantly, causing substantial damages to investors who purchased shares during the class period.

Securities class action on behalf of all persons and entities other than Defendants who purchased or otherwise acquired the common stock of Uber Technologies, Inc. pursuant and/or traceable to the Registration Statement issued in connection with Uber’s May 10, 2019 initial public stock offering, seeking to pursue remedies for Defendants violations of Sections 11, 12(a)(2), and 15 of the Securities Act of 1933.

Pursuant to the Plan of Allocations, all purchases of Uber Technologies common stock from May 10, 2019 through and including November 5, 2019, are deemed traceable to the offering.