Chung

I. BACKGROUND

1 A. Factual Background1 2 1. The Parties 3 Defendant Eargo, Inc. was founded in San Jose, California in 2010. Compl. ¶ 2 4 (dkt. 59). It went public in October 2020. Id. ¶ 3. Eargo makes and directly sells air 5 conduction hearing aids to people with mild-to-moderate hearing loss. Id. ¶ 31. Eargo’s 6 president and chief executive officer is Christian Gormsen, and its chief financial officer is 7 Adam Laponis. Id. ¶¶ 27–28. Both corporate officers are named as defendants in this suit, 8 along with members of Eargo’s board of directors, id. ¶ 315, and its IPO underwriters— 9 J.P. Morgan Securities LLC, BofA Securities, Inc., Wells Fargo Securities, LLC, and 10 William Blair & Company, L.L.C., id. ¶ 320. 11 Lead Plaintiffs are IBEW Local 353 Pension Plan, a multi-employer defined benefit 12 pension plan, and Xiaobin Cai, an individual. Id. ¶¶ 24–25. Lead Plaintiffs purchased 13 shares of Eargo common stock and now allege that they purchased the shares at artificially 14 inflated prices and suffered damages because of Defendants’ alleged violations of federal 15 securities laws. Id. They purport to represent investors who purchased or otherwise 16…