Dingdong purports to be a leading and the fastest growing on-demand e-commerce company in China. Dingdong’s mission is to “make fresh groceries as available as running water to every household.”
According to the complaint, the registration statement and prospectus used to effectuate the Company’s IPO misstated and/or omitted facts concerning Dingdong’s so-called commitment to ensuring the safety and quality of the food it distributes to the market. For example, despite claiming that it applies “stringent quality control across [its] entire supply chain to ensure product quality to [its] users,” Dingdong sold food past its sell-by date. Consequently, Dingdong was, in fact, no better at providing or assuring access to “fresh” groceries than the supermarkets, traditional Chinese wet markets, or traditional e-commerce platforms it repeatedly claimed to be displacing. Moreover, the foregoing conduct subjected Dingdong to an increased risk of regulatory and/or governmental scrutiny and enforcement, all of which, once revealed, were likely to (and did) negatively impact Dingdong’s business, operations, and reputation. In fact, as the truth about Dingdong’s business and its failure to meet its self-imposed food safety responsibilities reached the market, the value of the Company’s shares declined dramatically. By the commencement of the action, Dingdong’s shares traded as low as $2.51 per ADS, representing a decline of over 89% from the $23.50 IPO offering price.