Root investors may receive additional information about the case by clicking the link "Submit Your Information" above.

Root provides insurance products and services in the United States. Root has historically focused on auto insurance and operates a direct-to-consumer model that serves customers primarily through mobile applications, as well as through Root’s website.  Leading up to and following the IPO, Root described itself as an innovator in the personal insurance space with a new data- and technology-driven business model that was ready to disrupt traditional insurance markets and capture disproportionate market share, in part because of Root’s telematics-driven approach to insurance—i.e., the collection and transmission of vehicle-use data through devices.

On October 5, 2020, Root filed a registration statement on a Form S-1 with the Securities and Exchange Commission (“SEC”) in connection with the IPO, which, after several amendments, was declared effective on October 27, 2020 (the “Registration Statement”).  On October 28, 2020, Root conducted the IPO, selling 26.8 million shares of its Class A common stock to the public at $27.00 per share for total approximate proceeds of $724.43 million. On October 29, 2020, Root filed a prospectus on a Form 424B4 with the SEC in connection with the IPO, which incorporated and formed part of the Registration Statement (the “Prospectus” and, together with the Registration Statement, the “Offering Documents”).  Throughout the Class Period, the defendants misrepresented Root’s cash flow needs and auto-insurance business prospects.

The truth about Root’s cash flow needs and auto-insurance business prospects was revealed on March 9, 2021, when Bank of America Securities analyst Joshua Shanker (“Shanker”) initiated coverage of Root with an “Underperform” rating on the premise that Root is unlikely to be cash flow positive until 2027, finding that Root “will require not insignificant cash infusions from the capital markets to bridge its cash flow needs.” Shanker also noted that insurers Progressive, Allstate, and Berkshire Hathaway’s Geico would continue to impede Root’s profitability, with Progressive and Allstate having a “sizable advantage over Root in terms of amount of [telematics] data as well as engagement with the data” used to price their auto insurance.

Following this news, Root’s stock price fell $0.18 per share, or 1.46%, to close at $12.17 per share on March 9, 2021, representing a total decline of 54.93% from the Offering price.

The complaint alleges that the Offering Documents and the defendants made false and/or misleading statements and/or failed to disclose that: (i) Root would foreseeably fail to generate positive cash flow for at least several years following the IPO; (ii) accordingly, Root would foreseeably require significant cash infusions to meet its cash flow needs; (iii) notwithstanding the defendants’ touting of Root’s purportedly unique, data-driven advantages, several of Root’s established industry peers in fact possessed significant competitive advantages over Root with respect to, inter alia, telematics data and data engagement; and (iv) as a result, the Offering Documents and the defendants’ public statements throughout the Class Period were materially false and/or misleading and failed to state information required to be stated therein.

If you are a member of the class described above, you may no later than May 18, 2021 move the Court to serve as lead plaintiff of the class, if you so choose.

A lead plaintiff is a representative party that acts on behalf of other class members in directing the litigation. In order to be appointed lead plaintiff, the Court must determine that the class member’s claim is typical of the claims of other class members, and that the class member will adequately represent the class. Your ability to share in any recovery is not, however, affected by the decision whether or not to serve as a lead plaintiff. Filling out the online form above or communicating with any counsel is not necessary to participate or share in any recovery achieved in this case.  Any member of the purported class may move the court to serve as a lead plaintiff through counsel of his/her choice, or may choose to do nothing and remain an inactive class member.

If you wish to discuss this action or have any questions concerning this notice or your rights or interests with respect to these matters, please contact Kessler Topaz Meltzer & Check, LLP:  James Maro, Esq. (484) 270-1453 or Adrienne Bell, Esq. (484) 270-1435; toll-free at (844) 887-9500; or via e-mail at info@ktmc.com.  If you would like additional information about the suit, please click on the link "Submit Your Information" above and fill out the form as promptly as possible.