Wong

I. BACKGROUND

24 A. Factual Allegations 25 This is a putative class action for securities fraud brought by Lead Plaintiff Matis Nayman 26 (“Lead Plaintiff”) against Defendants Christine M. Gorjanc, Andrew W. Kim, Patrick C.S. Lo, and 27 Deutsche Bank Securities, Inc., Guggenheim Securities, LLC, Raymond James & Associates, Inc., Cowen and Company, LLC, and Imperial Capital, LLC (the “Underwriter Defendants”), and Arlo Technologies Inc., (collectively, the “Defendants”). Second Am. Compl. (“SAC”) ¶¶ 103-131, ECF 114. Defendant Arlo Technologies Inc. (“Arlo”) is a consumer electronics company that specializes in “smart home” security devices, such as cameras, doorbells, and lights. Id. ¶ 2. In August 2018, Arlo conducted an initial public offering (“IPO”) of its common stock. Id. ¶ 3. Arlo sold more than 11 million shares of common stock for $16.00 per share in its IPO. Id. ¶ 54. The IPO was underwritten by six financial institutions—the Underwriter Defendants. Id. ¶ 38. The Individual Defendants were officers and directors of Arlo during the IPO. Defendant Matthew McRae (“McRae”) was the Chief Executive Officer of Arlo and signed or…