The complaint alleges that the Offering Documents were negligently prepared and, as a result, contained untrue statements of material fact or omitted to state other facts necessary to make the statements made not misleading and were not prepared in accordance with the rules and regulations governing their preparation. The complaint continues to allege that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business, operations, and compliance policies. Specifically, the Offering Documents and Defendants made false and/or misleading statements and/or failed to disclose that: (1) Root would foreseeably fail to generate positive cash flow for at least several years following the IPO; (2) accordingly, the Company would foreseeably require significant cash infusions to meet its cash flow needs; (3) notwithstanding the Defendants' touting of Root's purportedly unique, data-driven advantages, several of the Company's established industry peers in fact possessed significant competitive advantages over Root with respect to, inter alia, telematics data and data engagement; and (4) as a result, the Offering Documents and Defendants' public statements throughout the Class Period were materially false and/or misleading and failed to state information required to be stated therein.

Current Root, Inc. shareholders who have held shares of the Company’s stock since the IPO date, October 28, 2020, can seek corporate reforms, the return of funds back to company coffers and potentially a court approved incentive award if appropriate. $ROOT