POET Technologies Inc.

The complaint alleges that POET Technologies misrepresented its tax status due to it likely being deemed a passive foreign investment company (or PFIC) under U.S. tax laws which, if not properly reported by each U.S. stockholder, would have negative tax implications for those U.S. stockholders; the foregoing tax issue would, if discovered, make POET Technologies a less attractive investment than it would otherwise be, thus threatening POET Technologies valuation. Additionally, Thomas Mika, despite affirming that he was not violating a non-disclosure agreement, in fact violated a business agreement by speaking about POET Technologies business agreements in a public interview, thus endangering POET Technologies business prospects, and as a result, defendants statements about POET Technologies business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.