According to the Complaint, Plaintiff wishes to inspect books and records relating to meetings of QuantumScape’s Board of Directors (the “Board”) regarding materially false and misleading statements concerning the Company’s solid-state batteries.
As alleged, public information about QuantumScape and its directors’ materially false and misleading statements supplies a credible basis to suspect wrongdoing that warrants investigation, including, for instance, the decision denying the Company’s motion to dismiss in an underlying securities class action, which found QuantumScape investors adequately stated securities fraud claims with respect to twenty-six statements under heightened pleading standards. That information, however, is insufficient for Plaintiff’s purpose of investigating that wrongdoing and for his separate but related purpose of investigating the independence of each of the Company’s directors and officers. Accordingly, Plaintiff seeks a summary Order from the Court of Chancery of the State of Delaware requiring the Company to produce the demanded books and records for inspection.
A copy of the Complaint can be viewed here:
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