This stockholder derivative action is brought on behalf of QuantumScape against certain current and former members of the Company’s Board of Directors (the “Board”) and other QuantumScape executives (collectively, the “Individual Defendants”) and Volkswagen Group of America Investments, LLC (“VGA” and, together with the Individual Defendants, “Defendants”) for (a) making and/or authorizing false and misleading statements and material omissions regarding the Company’s proprietary battery technology; and (b) failing to establish and/or oversee reasonable information, oversight, and reporting systems concerning mission-critical Company operations, including the adequacy of its public reporting.
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