Specifically, Defendants made false and / or misleading statements and / or failed to disclose that: (i) the Company was engaged in predatory lending practices that saddled subprime borrowers and / or those with poor or limited credit histories with high - interest rate debt that they could not repay; (ii) many
of the Company's
customers were using Qudian - provided loans to repay their existing loans, thereby inflating the Company's revenues and active borrower
numbers and increasing the likelihood
of defaults; (iii) the Company was providing online loans to college students despite a governmental ban on the practice; (iv) the Company was engaged overly aggressive and improper collection practices; (v) the Company had understated the
number of its non-performing loans in the Registration Statement and Prospectus; (vi) because
of the Company's improper lending, underwriting and collection practices it was subject to a heightened risk
of adverse actions by Chinese regulators; (vii) the Company's largest sales platform and strategic partner, Alipay, and Ant Financial, could unilaterally cap the APR for loans provided by Qudian; (viii) the Company had failed to implement necessary safeguards to protect
customer data; (ix) data for nearly one million Company
customers had been leaked for sale to the black market, including names, addresses, phone
numbers, loan information, accounts and, in some cases, passwords to CHIS, the state - backed higher - education qualification verification institution in China, subjecting the Company to undisclosed risks
of penalties and financial and reputational harm; and (
x) as a result
of the foregoing, Qudian's public statements were materially false and misleading at all relevant times.
Apple also opened up its Reserve and Pickup retail system in a
number of countries on November 4, allowing
customers to hold an iPhone
X at a brick - and - mortar Apple store from an online form, before visiting the store within the following 30 minutes.The list
of countries this was offered within included Australia, Belgium, the UK, Canada, Hong Kong, Switzerland, and the UAE.