According to the Complaint, Ibotta, Inc. purports to be a technology company that allows consumer packaged goods brands to deliver digital promotions to millions of consumers through its network called the Ibotta Performance Network. This lawsuit was filed against Ibotta, eight individual Defendants, and nine underwriter Defendants.

The Complaint alleges that statements made in the Registration Statement issued in connection with Ibotta's April 18, 2024 initial public offering were false and/or misleading when made because they did not properly warn investors of the risks concerning Ibotta’s contract with The Kroger Co. Kroger’s contract was at-will, and Ibotta failed to warn investors that a large client could cancel their contract with Ibotta without warning. Despite providing a detailed explanation of the terms of Ibotta’s contract with Walmart, there was not a single warning of the at-will nature of Kroger’s contract.

The Complaint further alleges that as a result of Defendants’ wrongful acts and omissions, and the precipitous decline in the market value of the Company’s common shares, Plaintiff and the other Class members have suffered significant losses and damages.